Ultimate Beneficiary Owner (UBO) Compliance

UBO of a company is the person who directly or indirectly controls and owns a company. Most recent regulations about ultimate beneficial ownership were implemented in the UAE according to the review of Cabinet Decision No. 58 of 2020. The Regulations are applicable to all entities incorporated in the UAE, whether such entities are located in mainland UAE or in any of the commercial free zones. All Relevant Entities are required to notify their respective registrar or licensing authority of its shareholders and real beneficiaries before the deadline given by respective authorities. The entities fully owned by federal and local governments are exempted from regulations.

The Regulation of procedures related to real beneficiaries, which was implemented on 28 August 2020 require all businesses registered in the UAE (subjected to exceptions) to maintain registers of their direct shareholders and their ultimate beneficial owners to submit those registers to their local regulatory authority through government approved legal ways.

According to the regulations, all relevant entities must maintain registers for the following:

Reasonable measures must be taken to acquire accurate information and keep the registers up-to-date date on a continuing basis and notify respective authorities of any changes to the information provided within 15 days of such change. Information related to its shareholders and real beneficiaries must be submitted to the respective authorities.

Identifying the Real Beneficiaries

Each relevant entity must identify its real beneficiaries being:

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