How did the UAE NRA 2024 assess legal persons and beneficial ownership risk?
The UAE ML/TF Risk Assessment 2024 assessed money laundering risk for legal persons and legal arrangements as medium-high. With hundreds of thousands of legal entities registered across mainland and free zones, the main vulnerability is the potential for complex structures and layered transactions to obscure the real beneficial owner, which can be exploited by third-party launderers.
This is why beneficial ownership transparency is a central plank of UAE AML policy. Regulated entities must identify and verify the beneficial owner behind their corporate customers, understand ownership and control structures, and keep that information current. Registrars and companies also have their own beneficial owner filing obligations. Where ownership is opaque or inconsistent with the customer’s profile, firms should apply enhanced due diligence.
Legal Reference (UAE):
· Cabinet Resolution No. 109 of 2023, Article 5 — obligation of entities to disclose and maintain accurate beneficial owner data.
· Federal Decree-Law No. 10 of 2025, Article 19(1)(b) — CDD, including beneficial owner identification, calibrated to risk.
For more details, consult the full text of Cabinet Resolution No. 109 of 2023 or seek guidance from your AML compliance officer.