The majority of cash-intensive businesses will be legal persons. Article 9 of AML-CFT Decision 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 should identify and verify the identity of the individual(s) holding the senior management position in the entity.

The beneficial owner of a legal person must be an individual. Another legal person cannot be classified as the beneficial owner of a customer, no matter what percentage it owns. LFIs should continue tracing ownership all the way up the ownership chain until it discovers 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 (10). If no individual qualifies as a beneficial owner, LFIs should identify the individual(s) holding the position of senior management officer(s) within the customer. This option should be used only as a last resort, however, and when the LFI is confident that no one individual, or small group of individuals, exercises control over the customer. Please see the CBUAE's Guidance for LFIs providing services to Legal Persons and Arrangements¹⁰ for more information on identification of beneficial owners.

¹⁰ Available at https://www.centralbank.ae/en/cbuae-amlcft.