# Must a UAE TCSP maintain a register of beneficial owners for its clients? **URL:** \ **Category:** UAE\ **Tags:** beneficial-owner, ubo, record-keeping\ **Created:** [July 30, 2026, 9:26am UTC](https://www.amlfaqs.com/t/must-a-uae-tcsp-maintain-a-register-of-beneficial-owners-for-its-clients/1295 "2026-07-30T09:26:38Z")\ **Posts on this page:** 4\ **Page:** 1
**Author:** ![Monika](https://yyz2.discourse-cdn.com/flex010/user_avatar/www.amlfaqs.com/monika/32/200_2.png) [@Monika](https://www.amlfaqs.com/u/Monika)\ **Post date:** [July 30, 2026, 9:26am UTC](https://www.amlfaqs.com/t/must-a-uae-tcsp-maintain-a-register-of-beneficial-owners-for-its-clients/1295/1 "2026-07-30T09:26:38Z")
Yes. Transparency of ownership sits at the heart of a TCSP’s role, and legal persons in the UAE must create and maintain a Real Beneficiary Register and a Partners or Shareholders Register with accurate, up-to-date information. A TCSP that forms or administers companies is closely involved in creating and keeping this information current. The register must record the beneficial owner’s details and be updated within fifteen days of any change, and the legal person must provide the information to the Registrar when requested. A TCSP acting as registered agent, director or nominee arranger must collect and verify beneficial ownership documentation, keep it current for the life of the relationship, and retain it under the record-keeping rules. Because corporate service work is precisely where ownership can be obscured, failure to maintain accurate registers is a serious compliance gap that exposes both the client entity and the provider to penalties. Registers and supporting documents should be retained for at least five years. **Legal Reference (UAE):** - [Cabinet Resolution No. 134 of 2025](https://rulebook.centralbank.ae/en/rulebook/cabinet-resolution-no-134-2025-regarding-executive-regulations-federal-decree-law-no-10), Article 39 - obligations relating to beneficial ownership data. - Cabinet Resolution No. 109 of 2023 on the Real Beneficiary Procedures, Article 8 - creation and updating of the Real Beneficiary Register. _For more details, consult the full text of Cabinet Resolution No. 109 of 2023 or seek guidance from your AML compliance officer._ [AML and CFT requirements for trusts and company service providers in the UAE](https://amluae.com/aml-and-cft-requirements-for-trusts-and-company-service-providers-in-the-uae/) ---
**Author:** ![pathik](https://yyz2.discourse-cdn.com/flex010/user_avatar/www.amlfaqs.com/pathik/32/5_2.png) [@pathik](https://www.amlfaqs.com/u/pathik)\ **Post date:** [July 30, 2026, 9:26am UTC](https://www.amlfaqs.com/t/must-a-uae-tcsp-maintain-a-register-of-beneficial-owners-for-its-clients/1295/2 "2026-07-30T09:26:39Z")
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**Author:** ![Monika](https://yyz2.discourse-cdn.com/flex010/user_avatar/www.amlfaqs.com/monika/32/200_2.png) [@Monika](https://www.amlfaqs.com/u/Monika)\ **Post date:** [September 10, 2026, 12:32am UTC](https://www.amlfaqs.com/t/must-a-uae-tcsp-maintain-a-register-of-beneficial-owners-for-its-clients/1295/3 "2026-09-10T00:32:44Z")
Company and trust service providers are DNFBPs when they act as an agent in incorporating legal persons, act or arrange for another to act as a director, secretary or partner, provide a registered office, business address, place of residence, correspondence address or administrative address, act or arrange for another to act as trustee of an express trust or in an equivalent function, or act or arrange for another to act as a nominee shareholder. The register duty falls primarily on the company itself rather than the service provider. Companies must obtain and retain basic information, up-to-date nominee director and nominee shareholder information, the partners’ or shareholders’ register, and beneficial owner information, updating within 15 working days of any change and verifying accuracy on an ongoing basis. Where the TCSP acts as trustee of a legal arrangement, Article 41 places parallel duties on it directly: obtain and retain adequate, accurate and up-to-date beneficial owner information, update within 15 working days, and retain for at least five years after its dealings end. **Legal Reference (UAE):** · [Cabinet Resolution No. 134 of 2025](https://rulebook.centralbank.ae/en/rulebook/cabinet-resolution-no-134-2025-regarding-executive-regulations-federal-decree-law-no-10), Article 3(5): the five TCSP activities; Article 38(1): company obligations to obtain, retain and update basic, nominee and beneficial owner information within 15 working days. · [Cabinet Resolution No. 134 of 2025](https://rulebook.centralbank.ae/en/rulebook/cabinet-resolution-no-134-2025-regarding-executive-regulations-federal-decree-law-no-10), Article 41(2) and (3): trustee obligations to obtain, retain, update within 15 working days and keep for at least five years. _For more details, refer to the Executive Regulations or seek guidance from your AML compliance officer._ [Corporate KYC compliance tool](https://amluae.com/corporate-kyc-compliance-tool/) ---
**Author:** ![Monika](https://yyz2.discourse-cdn.com/flex010/user_avatar/www.amlfaqs.com/monika/32/200_2.png) [@Monika](https://www.amlfaqs.com/u/Monika)\ **Post date:** [September 25, 2026, 12:02pm UTC](https://www.amlfaqs.com/t/must-a-uae-tcsp-maintain-a-register-of-beneficial-owners-for-its-clients/1295/4 "2026-09-25T12:02:08Z")