The UAE requires all mainland and free zone companies to maintain a register of their ultimate beneficial owners and to file this information with the relevant registration authority. Introduced as part of the UAE's AML framework reforms, the UBO register requirement is enforced through significant fines and can affect your ability to maintain banking relationships. This guide explains what is required and how to ensure compliance.
What Is a UBO and Who Must Register?
An Ultimate Beneficial Owner is the natural person who ultimately owns or controls 25% or more of a company's shares or voting rights, or who otherwise exercises ultimate effective control over the company. All UAE onshore and free zone companies (excluding listed companies and entities regulated by CBUAE, SCA, DFSA, or FSRA) must maintain a UBO register and file it with their licensing authority. The register must be updated within 15 days of any change in UBO information.
Information Required in the UBO Register
The UBO register must include: the UBO's full legal name, nationality, date and place of birth, usual residential address, nature of the beneficial interest (shareholding percentage, directorship, or other means of control), and the date on which the person became a UBO. Where the UBO is an entity rather than a natural person, the chain of ownership must be traced until a natural person is identified. Companies must also maintain a register of their nominee shareholders and directors.
Filing with the Licensing Authority
For mainland Dubai companies, UBO information is filed through the DED's Invest in Dubai portal. Other emirates have their own filing portals. Free zone authorities require UBO information to be submitted directly to the free zone authority and updated at each licence renewal. The information filed is maintained in a central register accessible to UAE regulatory and law enforcement authorities. It is not currently publicly available in the UAE.
Penalties for Non-Compliance
Failure to maintain or file the UBO register carries fines of AED 100,000 to AED 1 million depending on the nature of the violation. Banks routinely request UBO declarations as part of their KYC process and failure to provide up-to-date UBO information can result in account freezes or refusal of new facilities. Gulf Oasis Business Management maintains UBO registers for its managed clients and ensures timely filing with all relevant authorities.