Who qualifies as an Ultimate Beneficial Owner for a UAE DNFBP customer?
For a UAE Designated Non-Financial Business or Profession (DNFBP), the Ultimate Beneficial Owner (UBO) of a corporate customer is the natural person who ultimately owns or controls that customer. Identifying the UBO is a core part of customer due diligence, because a company can never itself be the true beneficiary of a transaction.
The primary test is ownership: a natural person who owns or controls, directly or indirectly, 25% or more of the shares or voting rights in the legal person is a beneficial owner. Where no such person can be identified, or there is doubt that an owner at that level is the beneficial owner, the test moves to whoever exercises control over the legal person by other means. If control still cannot be established, the natural person holding the senior management position is treated as the beneficial owner as a last resort. Corporate layering, nominee arrangements and trusts do not excuse the DNFBP from looking through to the natural person.
The DNFBP must verify the UBO’s identity, keep the information current, and retain it for at least five years.
Legal Reference (UAE):
· Cabinet Resolution No. 134 of 2025, Article 10 — beneficial owner is the natural person owning or controlling 25% or more, with fallback control and senior-management tests.
· Federal Decree-Law No. 10 of 2025, Article 19(3) — the Cabinet regulates the procedures for identifying the beneficial owner.
For more details, consult the full text of Cabinet Resolution No. 134 of 2025 or seek guidance from your AML compliance officer.