Who is considered a beneficial owner under UAE AML law?
Under the UAE AML framework, the beneficial owner is the natural person who ultimately owns or exercises effective control over a customer, or the natural person on whose behalf a transaction is conducted. The concept always points to a real individual rather than a company or legal arrangement, so that the person who genuinely controls or benefits from an entity cannot hide behind corporate layers.
For legal persons, regulated entities must identify the natural person who ultimately owns or controls a 25 percent or greater interest. Where no such person can be identified, or there is doubt, they must identify the natural person who exercises control by other means, and failing that, the relevant senior managing official. For legal arrangements such as trusts, the trustee, settlor, protector, and beneficiaries must be identified. Nominee shareholders and nominee directors are not treated as beneficial owners merely by holding shares or acting in a nominee capacity.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 10 — identification of the beneficial owner.
· CBUAE Rulebook – Identification of Beneficial Owners — supervisory guidance on beneficial ownership.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.
The complete guide to ultimate beneficial owner verification