Due Diligence

Federal Decree-Law No. 10 of 2025 on anti-money laundering, in force since 14 October 2025 and replacing Federal Decree-Law No. 20 of 2018, defines customer due diligence as the process of identifying and verifying the information of a customer or beneficial owner, whether a natural or legal person or a legal arrangement, identifying the nature of their business, the purpose of the business relationship and the ownership and control structure, including ongoing monitoring. That is the yardstick we apply when we check a counterparty, a target or a new client for you: identity, ownership, control and purpose, each verified against reliable documents rather than assumed, and then monitored for as long as the relationship lasts.

Sources: UAE Legislation Portal (uaelegislation.gov.ae) — Federal Decree by Law No. (10) of 2025 on anti-money laundering and combating the financing of terrorism and proliferation financing; UAE Legislation Portal (uaelegislation.gov.ae) — Federal Decree by Law No. (10) of 2025 on anti-money laundering and combating the financing of terrorism and proliferation financing — legislation record (accessed 24 October 2026)

The natural person at the top. Federal Decree-Law No. 10 of 2025 defines the beneficial owner as the natural person who owns or exercises ultimate effective control over the customer, or on whose behalf transactions are conducted, including anyone who exercises ultimate effective control over a legal person or arrangement directly or through a chain of ownership, control or other indirect means. For UAE companies, Cabinet Decision No. 109 of 2023 fixes the registrable threshold at 25 per cent or more of capital or voting rights, or control by other means such as the right to appoint or dismiss the majority of directors. We trace the chain until we reach a named individual.

Sources: UAE Legislation Portal (uaelegislation.gov.ae) — Federal Decree by Law No. (10) of 2025 on anti-money laundering and combating the financing of terrorism and proliferation financing; UAE Cabinet (text published by Dubai Development Authority) — Cabinet Decision No. (109) of 2023 On Regulating the Beneficial Owner Procedures (accessed 24 October 2026)

Through the commercial register and the company's own registers, not the share purchase agreement. Article 79 of Federal Decree-Law No. 32 of 2021 makes an assignment or pledge of an LLC stake valid against the company and third parties only from the date it is recorded in the commercial register with the competent authority, and Article 74 requires the company to keep a special register of partners at its headquarters. Cabinet Decision No. 109 of 2023 adds the register of beneficial owners that every licensed legal person must maintain. In our legal and structural due diligence we reconcile all three; a mismatch between them is a finding, not a formality.

Sources: UAE Legislation Portal (uaelegislation.gov.ae) — Federal Decree-Law No. (32) of 2021 on Commercial Companies; UAE Cabinet (text published by Dubai Development Authority) — Cabinet Decision No. (109) of 2023 On Regulating the Beneficial Owner Procedures (accessed 24 October 2026)

Yes. Trust and company service providers are designated non-financial businesses and professions supervised by the Ministry of Economy and Tourism for anti-money laundering purposes, alongside real estate agents and brokers, dealers in precious metals and stones, and independent accountants and auditors. Article 19 of Federal Decree-Law No. 10 of 2025 requires us to identify, assess, document and continuously update the money-laundering risks within our business, to implement customer due diligence and continuous monitoring scaled to those risks, and to retain the information obtained. That is why we ask every client for identity, ownership and source-of-funds documents before we act: it is a legal duty, not a commercial preference.

Sources: Ministry of Economy and Tourism — Combating Money Laundering, Terrorist Financing and Proliferation Financing; UAE Legislation Portal (uaelegislation.gov.ae) — Federal Decree by Law No. (10) of 2025 on anti-money laundering and combating the financing of terrorism and proliferation financing (accessed 24 October 2026)

Before, as a rule. The joint AML/CFT Guidelines for Designated Non-Financial Businesses and Professions issued by the UAE supervisory authorities in 2019 state that DNFBPs are obliged to undertake customer due diligence measures either prior to or during the establishment of a business relationship or the opening of an account, or prior to executing a transaction for a customer with whom there is no business relationship, and when carrying out occasional transactions of AED 55,000 or more. Deferral is permitted only in limited cases. In a transaction this means the counterparty checks run alongside the commercial negotiations, not after signing. We sequence them so completion is not delayed.

Source: UAE AML/CFT Supervisory Authorities (text published by Dubai Development Authority) — Anti-Money Laundering and Combating the Financing of Terrorism and Illegal Organisations: Guidelines for Designated Non-Financial Businesses and Professions (accessed 24 October 2026)

It must be reported, not just declined. Article 18 of Federal Decree-Law No. 10 of 2025 requires financial institutions, designated non-financial businesses and professions and virtual asset service providers that suspect, or have reasonable grounds to suspect, that a transaction or funds represent proceeds of crime or are related to it, regardless of value, to notify the Financial Intelligence Unit without delay and directly through its electronic system, with all available information, and confidentiality cannot be invoked to withhold it. Our AML reporting officer files that report through goAML where the law requires. A client or counterparty who fails our due diligence is therefore not simply turned away.

Source: UAE Legislation Portal (uaelegislation.gov.ae) — Federal Decree by Law No. (10) of 2025 on anti-money laundering and combating the financing of terrorism and proliferation financing (accessed 24 October 2026)

Its register of partners or shareholders, its register of beneficial owners, and evidence that both were filed with the licensing authority. Cabinet Decision No. 109 of 2023 requires a legal person applying for registration or a licence to provide the registrar with essential data about itself, to keep the details of each beneficial owner in a dedicated register, to submit that register and the partners' register to the registrar within 60 days of licensing, and to notify changes within 15 days. Ajman Free Zone's guidance puts it simply: companies must prepare and maintain these records on their premises. If a target cannot produce them promptly, we treat that as a compliance red flag in the report.

Sources: UAE Cabinet (text published by Dubai Development Authority) — Cabinet Decision No. (109) of 2023 On Regulating the Beneficial Owner Procedures; Ajman Free Zone Authority — Ajman Free Zone | UBO (accessed 24 October 2026)