Commercial Intelligence & Market Research across borders

Sources for the worked example

Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.

1. A beneficial owner is a natural person who owns or ultimately controls a legal person directly or indirectly through 25% or more of the ownership, or who controls it by other means such as the right to appoint or remove most directors. Mainland and non-financial free zone legal persons. Excluded entities are set out in ae-establish-009. Where no person meets the test, the resolution provides fallback rules.

   UAE Legislation Platform — Cabinet Resolution No. (109) of 2023 Regulating the Real Beneficiary Procedures · Article 5(1) · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

   Cabinet Resolution No. 109 of 2023 replaced Cabinet Resolution No. 58 of 2020. JAFZA's guidance gives 15 December 2023 as its effective date; the resolution itself says it takes effect the day after Official Gazette publication.

2. Under the UAE beneficial owner resolution, the Ministry and the registrar may not disclose data in the beneficial owner register or the partners or shareholders register without written approval, except for disclosures the resolution itself requires and under international laws and agreements in force in the UAE; the registers are provided to relevant UAE authorities on request. Federal; mainland and non-financial free zone legal persons covered by Cabinet Resolution No. 109 of 2023. The ministry must also facilitate access by competent foreign authorities to basic data. There is no general public access.

   UAE Legislation (uaelegislation.gov.ae) — Cabinet Resolution No. (109) of 2023 Regulating the Real Beneficiary Procedures · Articles 16 and 17 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

   Read in the official English translation. Financial free zones (DIFC, ADGM) run their own regimes, which were not researched.

3. Any person in the UAE must freeze, without prior notice, funds owned or controlled by persons on the UN Sanctions List or the UAE Local Terrorist List within 24 hours of the listing decision. Applies to all persons in the UAE; financial institutions and designated non-financial businesses must also screen records and transactions (Article 21).

   Ministry of Economy and Tourism (publisher) — Cabinet Decision No. 74 of 2020 Regarding the UAE List of Terrorists and Implementation of UN Security Council Decisions · Articles 1 (definition of Without Delay) and 15(1) · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

4. The UAE competition law prohibits agreements between undertakings that aim or result in restricting competition, including directly or indirectly fixing selling or purchasing prices, collusive tendering and sharing markets or customers by geographical area. Federal; Article 5 of Federal Decree-Law No. 36 of 2023. Market sharing is subject to the commercial agencies law. Individual and category exemptions are possible under Articles 9 and 11.

   Ministry of Economy and Tourism (UAE) — Federal Decree-Law No. (36) of 2023 Regulating Competition · Article 5(1)(a), (c) and 5(2)(a) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

5. Under the UAE competition law, an undertaking in a dominant position, or one exploiting another's economic dependence on it, may not directly or indirectly impose resale prices or conditions. Federal; Articles 6(1)(a) and 7(1). Violations of Articles 5 to 8 carry a fine of not less than AED 100,000 and up to 10% of the violator's annual sales in the State in the last financial year (Article 24).

   Ministry of Economy and Tourism (UAE) — Federal Decree-Law No. (36) of 2023 Regulating Competition · Articles 6(1)(a), 7(1) and 24 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

6. A UAE undertaking is in a dominant position when its market share, alone or jointly with others, exceeds 40% of total transactions in the relevant market. Federal; Cabinet Decision No. 3 of 2025, Article 2. The same decision sets merger notification thresholds of AED 300 million in annual UAE sales or a 40% combined share.

   Ministry of Economy and Tourism (UAE) — Cabinet Decision No. (3) of 2025 on the Thresholds Related to the Implementation of Federal Decree-Law No. (36) of 2023 Regulating Competition · Article 2 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

   Issued 20 January 2025 and effective 60 days after Official Gazette publication; the publication date was not stated in the text read.

7. For client due diligence, a beneficial owner of a company is a natural person who, alone or with others, has a controlling ownership interest of more than 10% of the shares, capital or profits of the company. Rule 9(3)(a), PML (Maintenance of Records) Rules 2005; partnerships also use 10% and unincorporated associations 15%. Central rule.

   Financial Intelligence Unit-India (FIU-IND), Ministry of Finance — Prevention of Money-laundering (Maintenance of Records) Rules, 2005, as amended · Rule 9(3) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

   Other limbs of the definition (control through other means, senior managing official) were not checked.

8. India's Competition (Amendment) Act, 2023 widened section 3(4) to cover any other agreement amongst enterprises or persons, including but not restricted to those at different stages of the production or supply chain, and excluded agreements between an enterprise and an end consumer. Central law. The amendment also extended tie-in, exclusive dealing and related categories to services.

   Competition Commission of India — The Competition (Amendment) Act, 2023 · Section 4(b), amending section 3(4) of the Competition Act, 2002 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

   The original 2002 Act text of section 3(4) and its appreciable adverse effect test could not yet be checked.

9. Since the 2023 amendment, the Competition Commission of India can impose a penalty of up to 10% of the average of the last three financial years' turnover or income, with turnover defined as global turnover from all products and services. Central law; section 27 as amended. For cartels the Commission may instead impose up to three times profit, or 10% of turnover, for each year of the cartel, whichever is higher.

   Competition Commission of India — The Competition (Amendment) Act, 2023 · Section 20(b), amending section 27 (Explanation 2) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

10. Anyone may inspect the German commercial register (Handelsregister) and the documents filed with it, for information purposes, by individual electronic retrievals. Federal; section 9(1) of the Commercial Code (HGB). The Länder designate the electronic system used.

    Federal Ministry of Justice (gesetze-im-internet.de) — Handelsgesetzbuch (HGB), section 9: Einsichtnahme in das Handelsregister · section 9(1) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

11. A beneficial owner of a company is any natural person who directly or indirectly holds more than 25 percent of the capital, controls more than 25 percent of the voting rights or exercises comparable control; if none can be identified, the legal representative or managing partner is deemed the beneficial owner. Companies other than registered foundations and listed companies subject to equivalent transparency rules.

    Bundesministerium der Justiz / Bundesamt für Justiz (gesetze-im-internet.de) — § 3 GwG – Wirtschaftlich Berechtigter · § 3 Abs. 2 GwG · Checked 18 October 2026 · Checked against an official source · Not yet professionally reviewed

12. Where the German Transparency Register is accessible, it shows a beneficial owner's first and last name, date of birth, place of residence, nature and extent of the economic interest, and all nationalities. Federal; section 19(1) GwG, subject to the access rules in section 23.

    Federal Ministry of Justice (gesetze-im-internet.de) — Geldwäschegesetz (GwG), section 19: Angaben zum wirtschaftlich Berechtigten · section 19(1) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

13. In Germany, the Transparency Register may be inspected by authorities and courts for their statutory tasks, by obliged entities that explain the access serves their customer due diligence, and by anyone else only if they prove a legitimate interest to the registry. Federal; section 23(1) of the Money Laundering Act (GwG). Details of the demonstration requirements can be set by Federal Ministry of Finance regulation.

    Federal Ministry of Justice (gesetze-im-internet.de) — Geldwäschegesetz (GwG), section 23: Einsichtnahme in das Transparenzregister · section 23(1) sentence 1 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

14. The EU vertical block exemption applies only if the supplier's market share does not exceed 30% of the market on which it sells and the buyer's share does not exceed 30% of the market on which it buys. EU; agreements capable of affecting trade between Member States. Agreements above the threshold are not presumed unlawful but need individual assessment.

    European Union (EUR-Lex) — Commission Regulation (EU) 2022/720 on the application of Article 101(3) TFEU to categories of vertical agreements and concerted practices · Article 3(1) · In force from 1 June 2022 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

15. Under the EU vertical block exemption, restricting a buyer's ability to set its own sale price is a hardcore restriction, although a supplier may set a maximum or recommend a price provided it does not become a fixed or minimum price through pressure or incentives. EU; hardcore restrictions remove the benefit of the block exemption for the whole agreement.

    European Union (EUR-Lex) — Commission Regulation (EU) 2022/720 on the application of Article 101(3) TFEU to categories of vertical agreements and concerted practices · Article 4(a) · In force from 1 June 2022 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

16. Germany applies the EU block exemption regulations correspondingly to agreements that are not capable of affecting trade between EU Member States, so the EU vertical rules also govern purely domestic German distribution agreements. Federal; section 2(2) of the Act against Restraints of Competition (GWB).

    Federal Ministry of Justice (gesetze-im-internet.de) — Gesetz gegen Wettbewerbsbeschränkungen (GWB), section 2: Freigestellte Vereinbarungen · section 2(2) · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

17. The UN Security Council Consolidated List includes all individuals and entities subject to measures imposed by the Security Council, while each sanctions committee publishes its own list of names and the measures that apply. UN Member States must implement the measures; questions on the list go to the UN Secretariat.

    Ministry of Foreign Affairs, Kingdom of Saudi Arabia — UN Security Council sanctions lists · Description of the Consolidated List · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

    The UN's own page (un.org, redirecting to main.un.org) could not yet be checked; the description is taken from the Saudi foreign ministry page.

18. The European Commission publishes a consolidated list of individuals, groups and organisations subject to EU financial sanctions, which reflects the adopted texts published in the Official Journal of the EU, and an EU Sanctions Map detailing all EU sanctions regimes and their legal acts. EU Member States. The consolidated list is published as the Financial Sanctions Files.

    European Commission (DG FISMA) — Overview of sanctions and related resources · Consolidated list and EU Sanctions Map entries · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed

19. On 22 November 2022 the Court of Justice of the EU, in joined cases C-37/20 and C-601/20, held Article 1(15)(c) of Directive 2018/843 invalid in so far as it required beneficial ownership information to be accessible in all cases to any member of the general public. EU Member States' central beneficial ownership registers. The ruling removed the EU-law basis for unrestricted public access; access by authorities and obliged entities was not affected.

    Court of Justice of the European Union (via EUR-Lex) — Judgment of the Court (Grand Chamber), Joined Cases C-37/20 and C-601/20 (WM and Sovim SA v Luxembourg Business Registers) · Operative part · In force from 22 November 2022 · Checked 19 October 2026 · Checked against an official source · Not yet professionally reviewed