As from 1 July 2019, all new business partners registering as an FZLLC or as a Branch Office of a foreign (non-UAE) Company will be required to complete and submit the UBO Form as part of the registration and licensing process. All existing business partners registered as an FZLLC or as a Branch Office of a foreign (non-UAE) Company will be
required to complete and submit the UBO Form as part of their licence renewal .
All companies registered in the UAE, including the free zones, are subject to the registration procedures with the Beneficial Owner data, with the exception of Public Shareholding companies and companies owned 100% by federal or local government agencies or companies affiliated with companies owned 100% by the UAE as well.
Entities which are licensed in the UAE but which are owned by a company listed on a recognized stock exchange subject to disclosure requirements which ensure sufficient transparency on its beneficial owners, or a company wholly-owned by such a listed company, are exempted from the requirement to implement reasonable procedures to obtain and maintain adequate and up-to-date information in respect of Ultimate Beneficial Owners.The UBO Register must include the following for each UBO:
The Shareholder/Partner Registers must include the following for each partner or shareholder:
- Full name, nationality, and date and place of birth
- Place of residence or notice address.
- Passport or identification number, country, and date of issue and expiry.
- The basis on which the natural person is identified as a beneficiary.
- The date on which the person became a UBO, and if applicable, the date on which they ceased to be one.
- The number and class of shares/equity held, and the voting rights attached.
- The date on which the shareholder/partner acquired the shares/equity.
- For shareholders/partners that are natural persons, the same information is required as for UBOs.
- For shareholders/partners that are legal entities:
- Name, legal form, and memorandum/articles association.
- Address of main office or headquarters, and if the legal entity is foreign, the name and address of its legal representative in the UAE must be included.
- Names of the persons holding senior management positions (including their passport or identification number, country of issue, date of issue, expiry date).
Failur to submit the UBO , before the deadline will attract a penalty of upto AED 100,000
Having professional help from a third-party like Alliott Management Consulting, can make the UBO registration process easier for your company. It will also make sure that you meet all requirements on time and without any issue.
The Ultimate Beneficial Owner [UBO] is the natural person who ultimately owns or controls the Legal Person , directly or indirectly, owns and controls a company. Individuals with ownership of at least 25% shares or voting rights of a company, or someone with the power to dismiss and appoint a majority of a company’s directors is considered as a UBO.