What are the AML obligations of nominee shareholders and directors in the UAE?
Nominee shareholders and nominee directors sit at the centre of AML transparency concerns because they can be used to hide the person who really owns or controls a company. Under UAE AML law a nominee is not treated as the beneficial owner merely by holding shares or performing management functions on someone else’s instructions; the real controller behind them must still be identified.
The Executive Regulations require the regime to regulate the obligations of companies, nominee directors and nominee shareholders. In practice a nominee must disclose their nominee status and the identity of the person on whose behalf they act, so that registrars and service providers can record the true beneficial owner. A company service provider that arranges nominees must apply due diligence to both the nominee and the underlying controller, and treat undisclosed or unexplained nominee arrangements as a red flag warranting closer scrutiny or a report.
Legal Reference (UAE):
· Federal Decree-Law 10/2025, Article 19(2)(c) — the Executive Regulations regulate the obligations of nominee directors and shareholders.
· Cabinet Resolution 134/2025, Article 3(5) — brings arranging nominee roles within DNFBP activity.
For more details, consult the full text of Cabinet Resolution 134/2025 or seek guidance from your AML compliance officer.
Money laundering risk associated with nominee shareholders and directors