Who qualifies as a beneficial owner under UAE AML law?
A beneficial owner is the natural person who ultimately owns or controls a legal person, whether directly or indirectly. Under the UAE’s real beneficiary rules, this includes any individual who owns or controls twenty-five per cent or more of a company’s capital, or who holds twenty-five per cent or more of its voting rights, including through the right to appoint or dismiss the majority of its directors.
Where no individual meets the ownership or voting test, the beneficial owner is the natural person who otherwise exercises ultimate control over the legal person by other means. If that still cannot be established, the person holding the position of senior managing official is treated as the beneficial owner.
For regulated entities, identifying the real beneficial owner behind a corporate customer is a core due diligence obligation. Verification should use reliable and independent source documents, and the analysis must look through layered ownership structures rather than stopping at the first corporate shareholder. Nominee arrangements that obscure the true owner are a recognised money laundering risk.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025 (Executive Regulations), Article 1 defines the beneficial owner as the natural person with ultimate ownership or control; Cabinet Resolution No. 109 of 2023, Article 5 sets the 25% ownership and voting test
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 (Executive Regulations) or seek guidance from your AML compliance officer.