SITUATION
A company received a UBO update request, but no changes were made to the License or MoA. What shall be done in this situation?
Answer
If no changes were made to the License or MoA, no UBO update is required. The request may be automatic/system-generated. However, to stay protected from fines, a few steps are recommended.
Legal Background
UAE UBO obligations are governed by Cabinet Decision No. 109 of 2023 on Beneficial Owner Procedures
Under this decision, a legal entity must periodically confirm the accuracy of its UBO data if requested by a regulatory authority and update information within 15 days of change.
Penalties for violations are set out in Cabinet Decision No. 132 of 2023 and can reach AED 100,000 depending on the type of violation
Note: Financial Free Zones are excluded from the provisions of Cabinet Decision No. 109 of 2023. Consequently, when dealing with DIFC or ADGM, there is a need to refer to the specialized legislative acts on UBO adopted by a certain financial free zone.
1. Is a UBO update required if th...