The short answer
UAE companies must keep a register of ultimate beneficial owners, meaning anyone holding 25% or more of capital or voting rights, and file it with their registrar. Firms in regulated sectors also need an AML programme and goAML registration. We build and maintain both, and prepare independent expert reports for courts and arbitration.
Who counts as an ultimate beneficial owner?
A natural person who ultimately owns or controls 25% or more of the company's capital or voting rights, or who otherwise controls it, is an ultimate beneficial owner (Jafza guidance on Cabinet Decision No. 109 of 2023). If nobody meets that test, the person who controls the company by other means, or failing that its senior manager, is recorded instead. Companies must keep a UBO register, a partners or shareholders register and a nominee register, and file them with the licensing authority.
When does a UBO declaration need updating?
Whenever the ownership or control picture changes: a share transfer, a new nominee arrangement, a change of manager where no 25% owner exists. Each registrar sets its own deadline and portal, so the practical rule is to file the update in the same week as the corporate change. Penalties for missing or inaccurate filings are set by Cabinet Resolution No. 132 of 2023.
“Holds an interest of a minimum of 25% capital of the legal entity.”
Does my business need an AML compliance programme?
Yes, if you operate in a sector designated under the UAE anti-money laundering law: real estate brokers, dealers in precious metals and stones, corporate service providers, auditors and accountants among them. A programme means a written business-wide risk assessment, customer due diligence procedures, an appointed compliance officer, staff training, goAML registration for suspicious transaction reporting, and periodic independent testing. We write the programme around how your business actually onboards customers.
What does a court-appointed financial expert do?
A financial expert gives the court an independent opinion on accounts, damages, profit shares or fraud, and the report is often what the judgment turns on. Typical cases include partnership disputes, unpaid contract claims, employee fraud and banking disputes. Our reports state the instructions, the documents reviewed, the method and the limits of each conclusion, so they hold up under the other side's questions.
What does corporate secretarial support include?
Board and shareholder resolutions, statutory registers, licence amendments and the annual filing calendar. For groups with several entities, we keep one compliance calendar covering licence renewals, audits, corporate tax returns and the registration deadlines that carry AED 10,000 penalties.
Frequently asked questions
Is UBO filing required for free zone companies?
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Yes. Mainland and free zone companies file with their own registrar; DIFC and ADGM have their own regimes.
Who should be the AML compliance officer?
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A senior, suitably qualified employee with direct access to management. Smaller firms sometimes combine the role with another; the regulator expects real independence either way.
Can you act as expert in arbitration as well as court?
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Yes. The method is the same; the instructions and procedural rules differ.
Sources
- Ultimate Beneficial Owners and Intermediate Beneficial Owners (Cabinet Decision No. 109 of 2023) — Jebel Ali Free Zone Authority (Jafza). Checked 16 October 2026.
- AED10,000 Penalty for Late Corporate Tax Registration (Cabinet Decision No. 10 of 2024) — UAE Ministry of Finance, 27 February 2024. Checked 16 October 2026.