What are the AML obligations of a trustee under UAE law?

UAE
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A trustee of an express trust, or a person holding an equivalent position in another legal arrangement, must obtain and hold adequate, accurate and current information on the identity of the settlor, the trustee, the protector, the beneficiaries or class of beneficiaries, and any other person exercising control over the arrangement. Acting as a trustee, or arranging for another to do so, is itself a regulated TCSP activity.

The trustee must keep basic information about other regulated agents and service providers to the trust, disclose their status to financial institutions and DNFBPs when forming a business relationship or carrying out a transaction above the threshold, and make the information available to the competent authorities on request. These duties apply to trustees administering arrangements in the UAE and, in defined cases, to foreign arrangements with a UAE nexus. The aim is to ensure that legal arrangements cannot be used to hide the natural persons who ultimately benefit from or control the assets.

Legal Reference (UAE):

For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.

AML regulations for TCSPs in UAE

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Trustees of trusts, and persons holding a similar or equivalent position in any other legal arrangement established or managed in the UAE, must obtain and retain adequate, accurate and up-to-date information on the beneficial owner. Where the parties to the arrangement are legal persons or other legal arrangements, they must obtain basic information and beneficial owner information for those too.

Three further duties apply. Retain basic information relating to supervised intermediaries and service providers, including investment advisers, managers, accountants and tax advisers. Maintain the information accurately, update it within 15 working days of any change, and retain it for not less than five years from the date dealings with the legal arrangement end. And disclose their status as trustee to financial institutions, DNFBPs and virtual asset service providers when establishing a business relationship or carrying out an occasional transaction above the prescribed threshold, cooperating with the concerned authorities on request.

Legal Reference (UAE):

· Cabinet Resolution No. 134 of 2025, Article 41(2): trustee duties to obtain and retain beneficial owner, basic and intermediary information.

· Cabinet Resolution No. 134 of 2025, Article 41(3) and (4): accuracy, the 15 working day update window, five-year retention, and disclosure of trustee status.

For your own circumstances, check your internal AML policy or speak to your compliance officer.

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