End-to-End UBO Identification & Mandatory Registry Filing
Ensure absolute alignment with UAE Cabinet Decision No. (109) of 2023 regarding Ultimate Beneficial Ownership.
The Regulatory Challenge & Non-Compliance Penalties:
Cabinet Decision No. (109) of 2023 strictly mandates that all commercial entities in the UAE identify, document, and register the Ultimate Beneficial Owner (UBO)—defined as the natural person who ultimately owns or controls 25% or more of the legal entity.
Penalty Risk: Failing to maintain an updated UBO Register or failing to report UBO declarations to corporate registrars results in immediate administrative fines up to AED 100,000, public administrative warnings, and commercial license suspension.
How It Works (The 4-Step Process)
- Ownership Mapping: We trace corporate shareholder chains layer-by-layer to identify the ultimate natural person(s).
- Threshold Application: We identify individuals holding equal to or greater than 25% voting rights or equity.
- Register Compilation: We draft the formal UBO Register as mandated by the Ministry of Economy.
- Registrar Submission: We file the official declaration with your commercial registrar and maintain continuous updates.
Applicable Sectors & Alignment
- Target Sectors: Corporate Service Providers, Trust Managers, All Mainland & Free Zone Entities across the UAE.
- Regulatory Alignment: Cabinet Decision No. (109) of 2023 on Ultimate Beneficial Ownership.
What We Deliver (Tangible Deliverables)
What We Deliver (Tangible Deliverables):
- Deep-dive ownership unraveling across multi-layered holding structures.
- Drafting of statutory Internal UBO Registers and Partner/Shareholder Registers.
- Official UBO declaration filings with relevant commercial licensing authorities.
- Ongoing monitoring mechanisms for changes in ownership structure (>25% shifts).
- Tangible Asset Received: Official Internal UBO Register + Registrar Submission Acknowledgment.
Service FAQ
Q: What if no single natural person owns 25% or more of the company?
A: Under Cabinet Decision No. (109), if no natural person holds 25%, the UBO is designated as the natural person who exercises control through senior management (e.g., Director or Senior Executive).