What are the fines for failing to keep a Real Beneficiary Register in the UAE?
Failing to maintain a Real Beneficiary Register carries administrative penalties in the UAE. These are set out in Cabinet Resolution No. 132 of 2023, which lists the fines for breaching the real beneficiary procedures established under Cabinet Resolution No. 109 of 2023. The registrar enforces the penalty schedule attached to the resolution.
Penalties are applied on an escalating basis. For example, failing to establish and maintain the Real Beneficiary Register with the required data attracts a fine in the region of AED 50,000 for a first violation, rising to about AED 100,000 for a repeat. Other breaches, such as not correctly registering the required real beneficiary details, attract lower fines that also increase on repetition. For a third-time violation, the registrar may go further and suspend the commercial licence and close the business premises of the offending legal person.
The practical message for UAE companies is that beneficial ownership record-keeping is not optional housekeeping. Registers must be created, kept accurate, updated when ownership changes, and filed with the relevant authority to avoid fines and the risk of licence suspension.
Legal Reference (UAE):
· Cabinet Resolution No. 132 of 2023 on Administrative Penalties — sets the fines for violating the real beneficiary procedures, escalating on repeat breaches.
For more details, consult the full text of Cabinet Resolution No. 132 of 2023 or seek guidance from your AML compliance officer.
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