Regulated nominee shareholder services with appropriate declaration of trust documentation and full UBO compliance.
Nominee shareholder arrangements serve legitimate purposes within international corporate structuring — from protecting commercial confidentiality in competitive markets to facilitating multi-layered holding structures where legal title and beneficial ownership are intentionally separated.
As a licensed TCSP, Polaris is authorised to act as nominee shareholder for client entities. All arrangements are documented through formal declarations of trust that clearly establish the beneficial ownership relationship and are disclosed to relevant regulatory authorities through Ultimate Beneficial Owner registrations.
Our nominee shareholder services are provided within a rigorous compliance framework. We do not offer arrangements designed to obscure beneficial ownership from regulators or to circumvent anti-money laundering obligations. Every engagement is subject to our standard KYC/AML due diligence, and all UBO disclosure requirements are satisfied in full.
Answers drawn from the published rules of the UAE authorities and regulators. Each answer links to its official source. Last reviewed 25 October 2026.
A person who holds shares and exercises the votes, or receives the dividends, on another person's instructions. Cabinet Resolution No. (134) of 2025 defines a Nominee Shareholder as a natural or legal person who exercises voting rights in accordance with the instructions of the Nominator, or receives dividends on their behalf, and who is not deemed the beneficial owner by virtue of holding shares in a nominee capacity. The Nominator is whoever gives those instructions, directly or indirectly. In our arrangements the relationship is documented in a declaration of trust, Polaris appears in the shareholder register as legal holder, and the Nominator, not Polaris, is recorded as the beneficial owner.
Source: UAE Ministry of Economy and Tourism (MoET) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (accessed 24 October 2026)
Yes. Cabinet Resolution No. (134) of 2025 lists acting, or arranging for another person to act, as a nominee shareholder for another person among the activities that make a firm a company and trust service provider, one of the designated non-financial businesses and professions under Federal Decree by Law No. (10) of 2025. Article 20 of that Decree-Law bars anyone from carrying on such an activity without a licence, registration or enrolment from the competent or supervisory authority, and the status brings the provider under the full anti-money laundering obligations of due diligence, record-keeping and reporting. Polaris acts as nominee shareholder under its corporate service provider licence and its registration with the Ministry of Economy as a designated non-financial business.
Sources: UAE Ministry of Economy and Tourism (MoET) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing; UAE Ministry of Economy and Tourism (MoET) — Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (accessed 24 October 2026)
In the company's Register of Partners or Shareholders and with the Registrar. Cabinet Decision No. (109) of 2023 requires a company whose partner or shareholder is a trustee or nominee to record that person in the register together with the data of the persons they represent, to update the register within 15 days of becoming aware of a change, and to submit it with the Beneficial Owner register to the Registrar within 60 days of licensing. Where shares are issued in the name of other persons, the details and identities must be disclosed to the Registrar within 15 days. Cabinet Resolution No. (134) of 2025 adds a 15-working-day update duty for nominee shareholder information. We prepare and file these entries for every nominee holding.
Sources: UAE Ministry of Economy and Tourism (MoET) — Cabinet Decision No. (109) of 2023 on Regulating the Beneficial Owner Procedures; UAE Ministry of Economy and Tourism (MoET) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (accessed 24 October 2026)
Increasingly, yes. Since 14 December 2025 Cabinet Resolution No. (134) of 2025 has required the Registrar to obtain a company's basic information together with the up-to-date information of any nominee director or nominee shareholder, verify it and make it publicly available. The beneficial owner behind the nominee is treated differently: the Registrar makes that information available to the concerned authorities, and Cabinet Decision No. (109) of 2023 prohibits the Ministry and the Registrar from disclosing the Beneficial Owner register or the Register of Partners or Shareholders to any person without the written approval of the beneficial owner or nominee, subject to exceptions for law enforcement and tax information exchange. Confidentiality is therefore from the public, never from the state.
Sources: UAE Ministry of Economy and Tourism (MoET) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing; UAE Ministry of Economy and Tourism (MoET) — Cabinet Decision No. (109) of 2023 on Regulating the Beneficial Owner Procedures (accessed 24 October 2026)
The Nominator. Cabinet Decision No. (109) of 2023 identifies the beneficial owner as the natural person who owns or exercises ultimate control over the company through 25 per cent or more of its capital or voting rights, directly, indirectly or through a chain of ownership, or through other means of control such as the right to appoint or dismiss the majority of directors; where no such person is found, the natural person controlling by other means, and failing that the senior management official. Cabinet Resolution No. (134) of 2025 states that a nominee shareholder is not deemed the beneficial owner by virtue of holding shares in a nominee capacity. The register therefore shows our name as legal holder and your name as beneficial owner.
Sources: UAE Ministry of Economy and Tourism (MoET) — Cabinet Decision No. (109) of 2023 on Regulating the Beneficial Owner Procedures; UAE Ministry of Economy and Tourism (MoET) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing (accessed 24 October 2026)
No. Cabinet Decision No. (109) of 2023 states that a legal person licensed or registered in the UAE should not issue bearer share warrants, and Cabinet Resolution No. (134) of 2025 goes further: no company established and registered in the UAE may issue bearer shares, bearer share warrants or any similar instrument that cannot be traced, and any issued before the Resolution had to be converted into registered shares within 30 working days of its publication, with holders notifying the company of their status first. A disclosed nominee holding is the only lawful way to separate legal title from beneficial ownership, which is why every Polaris nominee arrangement is registered and reported rather than kept in a drawer.
Sources: UAE Ministry of Economy and Tourism (MoET) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing; UAE Ministry of Economy and Tourism (MoET) — Cabinet Decision No. (109) of 2023 on Regulating the Beneficial Owner Procedures (accessed 24 October 2026)
Fines under Cabinet Resolution No. (132) of 2023, which sets the administrative penalties for breaches of Cabinet Decision No. (109) of 2023. Failing to establish the Register of Partners or Shareholders at all costs AED 50,000 on the first fine and AED 100,000 on the next; failing to update it within 15 days of a change draws a written warning first, then AED 15,000 and AED 30,000; and failing to hold the required details of each partner or shareholder costs AED 30,000 and then AED 60,000. The Registrar warns and fines in the same way for incomplete beneficial owner entries. Keeping the register is part of our nominee engagement, so the shareholder of record and the compliance file are maintained by the same hands.
Source: UAE Ministry of Economy and Tourism (MoET) — Cabinet Resolution No. (132) of 2023 Concerning the Administrative Penalties against Violators of the Provisions of the Cabinet Resolution No. (109) of 2023 Concerning the Regulation of Beneficial Owner Procedures (accessed 24 October 2026)
No. The declaration of trust is the private document that fixes your rights against us as legal holder of the shares; it does not replace the statutory disclosures and we never present it as doing so. Cabinet Resolution No. (134) of 2025 requires a nominee shareholder to notify the company of its capacity and disclose the identity of the person it represents, and Cabinet Decision No. (109) of 2023 requires the company's Register of Partners or Shareholders to include the data of the persons represented by each trustee or nominee. The declaration, the register entries and the Registrar filings therefore all name the same beneficial owner. We issue the declaration, make the notifications and keep the register in step with it.
Sources: UAE Ministry of Economy and Tourism (MoET) — Cabinet Resolution No. (134) of 2025 Regarding the Executive Regulations of Federal Decree by Law No. (10) of 2025 Regarding Anti-Money Laundering, and Combating the Financing of Terrorism and Proliferation Financing; UAE Ministry of Economy and Tourism (MoET) — Cabinet Decision No. (109) of 2023 on Regulating the Beneficial Owner Procedures (accessed 24 October 2026)
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