CBUAE Guidance for Licensed Financial Institutions Providing Services to Legal Persons and Arrangements

June 7, 2021

Contents

1. Introduction ... 4 1.1. Purpose of this Guidance ... 4 1.2. Applicability ... 4 1.3. Legal Basis ... 5 1.4. Definitions ... 5

2. Understanding and Assessing the Risks of Legal Persons and Arrangements ... 6 2.1. ML/TF risks legal persons and arrangements pose to LFIs ... 6 2.1.1. Obscuring identity/beneficial ownership ... 6 2.1.2. Obscuring the purpose of an account or transaction ... 7 2.1.3. Obscuring source of funds or of wealth ... 7 2.1.4. Common typologies of abuse of legal persons and arrangements ... 7 2.2. Features and Controls that Mitigate the Risk of a Legal Person or Arrangement ... 9 2.2.1. Formation requirements and process ... 9 2.2.2. Identification and reporting of beneficial owners ... 10 2.2.3. Reporting and Recordkeeping ... 10 2.2.4. Supervision ... 11

3. Legal persons and arrangements in the UAE ... 11 3.1. Identification of beneficial owners ... 11 3.2. Legal arrangements under UAE law ... 12 3.3. Economic Substance Requirements ... 13

4. Mitigating Risk ... 13 4.1. Requirements for legal person and arrangement custo...