Who is a beneficial owner that UAE accountants must identify?
A beneficial owner is the natural person who ultimately owns or controls a customer, or on whose behalf a transaction is being conducted. For a company, this typically means the individual who ultimately owns or controls, directly or indirectly, a defined shareholding or voting interest, or who otherwise exercises control through other means. Where no such person can be identified, the natural person holding the senior management position is treated as the beneficial owner.
UAE accountants must look through corporate layers, nominee arrangements, and legal arrangements such as trusts to reach the real individuals behind the client. Identifying only the immediate corporate customer is not enough. The firm must verify the beneficial owner’s identity using reliable, independent information and apply additional measures where ownership structures are complex or opaque, because such structures are a recognised money laundering vulnerability.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 6 — requires identification and verification of the beneficial owner alongside the customer.
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 12 — sets additional due diligence measures directed at the beneficial owner and ownership structures.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.
AML Compliance Requirements for Auditors and Accountants in the UAE