Who is the Ultimate Beneficial Owner (UBO) of a UAE company?
UAE law requires every company, Mainland or Freezone, to identify and declare the individual(s) who directly or indirectly hold at least 25% of the capital or voting rights, or who otherwise exercise effective control. This translates into several concrete steps:
- Identify each beneficial owner under the 25% threshold or the control test.
- Keep an up-to-date UBO register, available to the competent authority on request.
- Declare any change in shareholding or the control chain within the regulatory deadlines.
- Where applicable, comply with the AML/CFT obligations specific to the sector (DNFBPs in particular).
- Respond to information requests from regulators and banks as part of KYC checks.
Common failure points
The situations we handle.
- UBO register not updated after a change in shareholding.
- Confusion between the nominal shareholder and the real beneficial owner in a layered structure.
- Missing AML filings for DNFBP activities subject to a specific regime (real estate, precious metals, corporate service providers).
- Incomplete UBO file, a frequent cause of hold-ups when opening or maintaining a bank account.
Deliverables
What you get.
Shareholding mapping
Identifying beneficial owners across the full ownership chain.
UBO register
Building and maintaining the statutory register.
AML/CFT framework
Internal procedures adapted to your sector, where applicable.
Filing follow-up
Updates on every change in the capital structure.
Our approach
Our approach.
Identifying the beneficial owner conditions bank account opening, the credibility of the KYC file and, for some sectors, the licence itself. We trace the ownership chain up to the controlling individual, document the UBO register and, where the activity requires it, put in place the AML/CFT procedures expected by the regulator.
Mapping & register
Identifying beneficial owners and building the UBO register.
AML/CFT compliance
Internal procedures adapted for the activities concerned.
Ongoing monitoring
Updates on every change in shareholding.
Frequently asked
Ultimate Beneficial Owner (UBO) and AML compliance in the UAE — your questions.
Does the 25% threshold also apply to indirect structures?
Yes. Control is assessed across the entire ownership chain, including where the interest passes through one or more intermediary companies.
Are all companies subject to AML/CFT obligations?
No. The heaviest obligations target Designated Non-Financial Businesses and Professions (DNFBPs) — real estate, precious metals and stones, corporate service providers in particular — but the UBO register applies to all companies.
What does a company risk by not updating its UBO register?
Administrative sanctions, and in practice frequent hold-ups during bank checks or licence renewal.
Related practices and analysis
Related practices, and the analysis behind them.
A matter on UBO or AML compliance?
A 30-minute call to review your UBO register and your AML/CFT obligations.
See matters the firm has handled and what clients say about them.
AED 600 individuals · AED 1,000 professionals
Payable before the call, by card or bank transfer. See fee details.