The majority of DPMS and real estate sector customers will be legal persons. The UAE requires all financial institutions to identify the beneficial owners of a legal person customer by obtaining and verifying the identity of all individuals who, individually or jointly, have a controlling ownership interest in the legal person of 25% or more. Where no such individual meets this description, the LFI must identify and verify the identity of the individual(s) holding the senior management position in the entity.

Legal arrangements may be involved in transactions related to real estate. For legal arrangement customers, LFIs must verify the identity of the settlor, the trustee(s), or anyone holding a similar position, the identity of the beneficiaries or class of beneficiaries, the identity of any other natural person exercising ultimate effective control over the legal arrangement and obtain sufficient information regarding the beneficial owner to enable verification of his/her identity at the time of payment, or at the time he/she intends to exercise his/her legally acquired rights.

The beneficial owner of a legal person or arrangement must be an individual. Another legal person or arrangement cannot be the beneficial owner of a customer, no matter what percentage it owns. LFIs must continue tracing ownership all the way up the ownership chain until they discover all individuals who own or control at least 25% of the LFI's customer.

When the LFI has identified qualifying beneficial owners, it should perform CDD on each individual beneficial owner, in accordance with the requirements of Article 8.1(a) of AML-CFT Decision.

Please see the CBUAE's Guidance for Licensed Financial Institutions providing services to Legal Persons and Arrangements⁸ for more information on identification of beneficial owners.

⁸ Available at https://www.centralbank.ae/en/cbuae-amlcft