What is a Real Beneficiary Register and who must maintain it in the UAE?
A Real Beneficiary Register is a private register that a legal person must keep listing its beneficial owners along with their identifying details. It sits alongside the Partners or Shareholders Register. The obligation applies to legal persons licensed or registered in the UAE, with limited exceptions such as wholly government-owned companies and entities in the financial free zones, which have their own regimes.
The legal person must record each real beneficiary, keep the register up to date, and reflect any change within fifteen days. It must also submit the required information to the Registrar. For a DNFBP carrying out due diligence on a corporate customer, these registers are a key source for verifying who ultimately owns and controls the client.
Legal Reference (UAE):
· Cabinet Resolution No. 109 of 2023 (Real Beneficiary Procedures), Article 8 - requires the Real Beneficiary Register and updates within fifteen days.
· Cabinet Resolution No. 109 of 2023 (Real Beneficiary Procedures), Article 10 - requires the Partners or Shareholders Register.
For more details, consult the full text of Cabinet Resolution No. 109 of 2023 or seek guidance from your AML compliance officer.