Risk, Compliance & Financial Integrity in the United Arab Emirates

Full guide · Source-checked research100% of statements checked against a source133 checked against an official source9 checked against a secondary sourceChecked 2026-10-19Not yet professionally reviewed

• 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 · checked 2026-10-18

• Companies must keep a register of beneficial owners and submit any change in beneficial ownership information to the registrar within 15 days of the change.

  Entities covered by Cabinet Resolution No. 109 of 2023. Administrative penalties for breaches are set by Cabinet Resolution No. 132 of 2023 (not reviewed here).UAE Legislation Platform · checked 2026-10-18

• The beneficial owner resolution does not apply to companies in financial free zones, to companies wholly owned by the federal or a local government (or by their wholly owned companies), or to the government partner where a government is a shareholder.

  Financial free zones (the DIFC and ADGM) run their own beneficial ownership regimes. Companies owned by a listed company subject to adequate disclosure rules are also exempt from the duty to hold beneficial ownership information.UAE Legislation Platform · checked 2026-10-18

• Breaching the merger control provisions can lead to a fine of 2% to 10% of annual UAE sales or revenue from the goods or services concerned in the last financial year, or AED 500,000 to AED 5 million where that figure cannot be calculated.

  Federal.Ministry of Economy and Tourism · checked 2026-10-18

• The federal anti-money laundering and counter-terrorist and proliferation financing law is Federal Decree-Law No. 10 of 2025, with executive regulations in Cabinet Resolution No. 134 of 2025.

  Federal.Ministry of Economy and Tourism · checked 2026-10-18

• Designated non-financial businesses and professions under the AML executive regulations include commercial gaming operators, real estate brokers and agents, dealers in precious metals and stones, lawyers, notaries, other independent legal professionals and independent accountants, and company and trust service providers.

  Federal; supervisory authorities may designate further categories.Ministry of Economy and Tourism · checked 2026-10-18

• Customer due diligence is required on starting a business relationship and, for financial institutions, on occasional transactions of AED 55,000 or more and occasional wire transfers of AED 3,500 or more; dealers in precious metals and stones must apply it to cash transactions of AED 55,000 or more.

  Federal. Virtual asset service providers: occasional transactions of AED 3,500 or more (Article 7(3)); commercial gaming operators: AED 11,000 or more.Ministry of Economy and Tourism · checked 2026-10-18

• Reporting entities must file suspicious transaction reports with the Financial Intelligence Unit immediately and without delay, regardless of the transaction value.

  Federal; lawyers, notaries, other independent legal professionals and independent auditors are exempt in certain circumstances covered by professional secrecy (Article 18(2)).Ministry of Economy and Tourism · checked 2026-10-18

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