UBO and bank KYC

The bank asks for UBO details different from what I filed. Does it matter?

The situation

Yes. Banks apply their own customer due diligence, but your registrar filing and bank records should match. Differences raise AML questions.

The law

  • Cabinet Resolution 109 of 2023: Accurate beneficial owner data
  • Federal Decree-Law 10 of 2025: Banks identify beneficial owners

What it means for you

Example: you filed only yourself as owner but the bank sees a 30 percent investor in the memorandum. Correct the filing and give the bank the same information. Consistent data speeds up KYC refreshes.

What to do

  1. Compare the UBO filing with bank records.
  2. Correct the wrong one.
  3. Send the bank updated documents.
  4. Keep both in sync after changes.

We can do this for youBeneficial owner (UBO) register: identifying owners, filing with the registrar and updating changes: AED 750

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