How often must a UAE company update its beneficial owner register?
A UAE legal person must create a real beneficiary register and keep it current. Any change to the beneficial owner information must be recorded in the register within fifteen days of the company becoming aware of it. The register itself must be created within sixty days of the entity’s formation or of the rules taking effect, whichever applies, so the obligation begins early in a company’s life.
The register must hold each beneficial owner’s full name, nationality, date and place of birth, address, identity or passport details, the grounds and date on which the person became a beneficial owner, and the date they ceased to be one. A separate partners or shareholders register is also required and must be updated within fifteen days of any change. For TCSPs administering client entities, maintaining these registers accurately and on time is a practical part of their AML responsibilities.
Legal Reference (UAE):
· Cabinet Resolution No. 109 of 2023 (Real Beneficiary Procedures), Article 8 - requires creation of the register within sixty days and updates within fifteen days.
· Cabinet Resolution No. 109 of 2023, Article 10 - requires a partners or shareholders register updated within fifteen days.
For more details, consult the full text of Cabinet Resolution No. 109 of 2023 or seek guidance from your AML compliance officer.