Ultimate Beneficial Owner (UBO) Advisory

As a primary requirement of Anti-Money Laundering Regulation in the UAE, Cabinet Decision No. 58 of 2020 regulating the Beneficiary Owner Procedures requires all business entities (unless exempt by the regulation) to prepare, maintain and submit a Beneficial Owner Register with their respective licensing authorities.

The Beneficial Owner is an individual who owns 25% or more shares (directly or indirectly) or has absolute control over the UAE entity or the UAE entity’s senior management. Identifying the Beneficial Owner is a complex matter in the case of a corporate chain shareholding structure whereby several holding companies hold the UAE entity.

The Beneficial Owner’s passport details and address of the corporate shareholder’s entities that own the UAE entity must be included in the Beneficial Owner Register and Ultimate Beneficial Owner (UBO) declaration form before submission to the licensing authorities.

The Free Zone authorities in the UAE have opened their portal for the submission of the UBO for the respective FZ companies with specified deadlines, and the Department of Economic Development (DED) accepts submissions of the UBO Register, UBO Declaration Form, and Partners Register. The DED blocks licenses of entities that have failed to submit the required documents.

The UBO details have become crucial after the implementation of the Economic Substance Regulation (ESR) in the UAE, as the ESR Report requires details of the Ultimate Parent Company and Ultimate Beneficial Owner.

At AMA, our legal experts successfully help clients with:

  • Identification of Beneficial Owners
  • Preparation of all relevant and required documents such as UBO Register, UBO Declaration Form, and Partners Register
  • Compiling supporting documents required for the submission of UBO documents
  • Prompt submission of UBO documents to the DED
  • Submission of the UBO details in the company’s portal

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