Who is considered a beneficial owner under UAE AML law?
A beneficial owner is the natural person who ultimately owns or controls a customer or on whose behalf a transaction is conducted. In practice, UAE guidance treats a beneficial owner as an individual who owns or controls 25% or more of the shares or voting rights of a legal person, or who otherwise exercises effective control over its management.
Where no individual meets the ownership or control threshold, the natural person exercising control through other means is the beneficial owner; if none can be identified, a senior managing official is treated as the beneficial owner for compliance purposes. Identifying and verifying the beneficial owner is a mandatory part of customer due diligence, and the Cabinet is empowered to issue the detailed procedures for beneficial owner identification. Correctly piercing the corporate veil is essential to prevent misuse of legal persons for illicit finance.
Legal Reference (UAE):
· Federal Decree-Law No. 10 of 2025, Article 19(3) and Article 35 — require beneficial owner identification and penalise false beneficial owner information
For more details, consult the full text of Federal Decree-Law No. 10 of 2025 or seek guidance from your AML compliance officer.