UNITED ARAB EMIRATES Law and Practice Contributed by: Francesco Bulleri, Beshoy Mounir, Sultan Bahriddini and Noora Al Doseri, ADG Legal
details, changes to shareholders, directors, manag - ers or authorised signatories, share capital changes, licence renewals, annual filings and beneficial owner - ship information. Under Cabinet Decision No 109 of 2023 on regulating beneficial owner procedures, legal persons are required to maintain and submit beneficial owner information and partner or shareholder regis - ters to the relevant registrar, and to update changes within the prescribed period. Public availability depends on the relevant registry. Basic licence information may be available through official licence search portals and the UAE National Economic Register, which allows businesses to view certain licence details maintained by government authorities. In the DIFC and ADGM, public registers are also available which provide access to certain company information, including details relating to current and former shareholders and directors. That said, constitutional documents and beneficial owner - ship records are generally not publicly available. Failure to make required filings may result in adminis - trative penalties, licence suspension, inability to renew the licence, restrictions on amendments or other regu - latory action, depending on the applicable registry and breach. Registrars have supervisory powers to receive, main - tain and update corporate information, review filings, require corrections, impose or recommend adminis - trative measures, suspend or refuse licence renew - als, and share information with competent authorities. Under the beneficial ownership framework, registrars also play a role in maintaining beneficial ownership data and supporting AML/CFT transparency require - ments. 5.4 Global Anti-Money Laundering The UAE’s AML/CFT framework applies primarily to financial institutions, designated non-financial busi - nesses and professions, virtual asset service provid - ers and other regulated persons. However, regular (ie, non-regulated) companies are also affected through beneficial ownership, licensing, sanctions, record- keeping and corporate transparency requirements. The current federal AML framework is prescribed in Federal Decree-Law No 10 of 2025 on anti-money
laundering, combating the financing of terrorism and proliferation financing, together with its executive regulations and supervisory authority rules. Generally, entities must identify, assess, document and update their money-laundering, terrorist-financ - ing and proliferation-financing risks. They must also apply customer due diligence, monitor transactions, maintain records, implement internal policies and controls, appoint appropriate compliance personnel where required, and report suspicious transactions to the UAE Financial Intelligence Unit without delay where there are suspicions or reasonable grounds for suspicion. Boards and senior management are expected to oversee AML/CFT compliance through a risk-based framework. In practical terms, this requires the board or senior management to: • approve AML policies and procedures; • ensure that adequate systems and controls are implemented; • appoint and empower compliance personnel; • receive compliance reporting; • oversee remediation of deficiencies; and • ensure that suspicious transaction reporting and sanctions screening procedures operate effectively. The level of oversight expected will depend on the company’s regulatory status, size, activities, customer base and risk profile. Sanctions compliance is also central to the UAE AML/ CFT framework. The UAE implements financial sanc - tions under Cabinet Resolution No 74 of 2020, which concerns terrorism lists and the implementation of UN Security Council resolutions relating to terrorism financing, proliferation of weapons of mass destruc - tion and related matters. The UAE Ministry of Econo - my states that, as a UN member, the UAE implements Security Council sanctions through this framework. Directors and managers may face personal liability where AML/CFT non-compliance is attributable to their knowledge, involvement or breach of duties. Under the AML framework, supervisory authori - ties may impose administrative measures, including
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