Must UAE company service providers identify the beneficial owner?
Yes. Identifying and verifying the beneficial owner is a core obligation for company service providers, and it is precisely the point of the sector’s AML controls. The beneficial owner is the natural person who ultimately owns or exercises effective control over a customer, or on whose behalf a transaction is conducted, and a nominee holding shares or acting as director does not displace that person.
The provider must look through layers of ownership to the ultimate controlling individual, using reliable information rather than accepting the arrangement at face value. Where ownership is spread across corporate vehicles or jurisdictions, the provider must map the chain until it reaches natural persons and take reasonable measures to confirm their identity. Beneficial ownership information must be kept accurate and up to date, and shared with the registrar where required. Failure to establish the beneficial owner is a reason not to proceed and may trigger a suspicious transaction report.
Legal Reference (UAE):
· Federal Decree-Law 10/2025, Article 19(1)(b) — customer due diligence includes identifying the beneficial owner.
· Cabinet Resolution 134/2025, Article 6 — due diligence and beneficial owner identification measures.
For more details, consult the full text of Cabinet Resolution 134/2025 or seek guidance from your AML compliance officer.