Beneficial ownership across the six: where the line is drawn, and who may look at the register
Beneficial ownership is where customer due diligence meets company law. For an MLRO working across our six jurisdictions, two questions decide how much a register can do for you: where the ownership line is drawn, and whether you are allowed to look.
Beneficial ownership is where customer due diligence meets company law. For an MLRO working across our six jurisdictions, two questions decide how much a register can do for you: where the ownership line is drawn, and whether you are allowed to look.
This week’s series takes one question at a time and asks it of all six, with the UAE’s federal rules alongside DIFC and ADGM. We start with beneficial ownership, because almost every CDD file leans on it.
Where the line is drawn
25% in the UAE, ADGM, DIFC and Saudi Arabia. Onshore, Cabinet Decision No. 109 of 2023 treats as a beneficial owner whoever holds 25% or more of a legal person’s capital or voting rights, directly or indirectly. ADGM’s Beneficial Ownership and Control Regulations 2022 use 25% of ownership or voting rights for companies and LLPs. The DIFC Authority’s company handbook lists 25% of the shares or of the voting rights, among other tests. Saudi Arabia’s Ministry of Commerce describes its rules as starting from ownership of at least 25% of a company’s capital.
20% in Qatar and Mauritius. Qatar’s Ministry of Commerce and Industry identifies the beneficial owners of commercial companies as natural persons holding at least 20% of capital or voting rights. In Mauritius the Companies Act leaves the percentage to regulations, and the Companies (Beneficial Owner) (Percentage of Shares) Regulations 2019 set it at 20% whatever the type of share. For financial institutions the figure is instead the Banking Act’s “significant interest”.
Morocco: not confirmed. We could not confirm Morocco’s ownership threshold from an official document for this briefing, so we do not state one.
When no one crosses the line. The UAE, ADGM, Saudi Arabia and Qatar each step down to control by other means, and then to a named position: senior management in the UAE, an officer in ADGM, the manager, a board member or the chair in Saudi Arabia, and the company’s legal representative in Qatar. In the DIFC handbook, control is one of the tests, and each director is deemed a beneficial owner where no one meets any of them.
Who keeps the register, and who can see it
| Jurisdiction | Where the information goes | Threshold | Changes reported within | Can a bank or DNFBP see it? |
|---|---|---|---|---|
| UAE (onshore and commercial free zones) | The Registrar (the authority supervising the trade names register) | 25% | 15 days | No general right. The Ministry and the Registrar may not disclose without the beneficial owner’s written approval, subject to legal exceptions |
| ADGM | ADGM Registrar | 25% | 15 days | No. The record is not public, and only designated Registration Authority staff can access it |
| DIFC | DIFC Registrar of Companies | 25% | 30 days (DIFC Authority handbook) | Could not be confirmed for this briefing |
| Saudi Arabia | Ministry of Commerce database | 25% of capital | Could not be confirmed for this briefing | No. Access is restricted to regulatory bodies and competent authorities |
| Qatar | Unified Economic Register | 20% | 30 days from receiving the documents (90 days if they cannot be obtained) | Only for CDD, and only within the limits of the CDD the law requires |
| Mauritius | Registrar of Companies | 20% | Could not be confirmed for this briefing | The Act names only competent authorities and prescribed public-sector authorities |
| Morocco | OMPIC (public register of beneficial owners) | Could not be confirmed for this briefing | Could not be confirmed for this briefing | OMPIC publishes an access request form, with a fee of 180 dirhams for the beneficial-owner information sheet |
One UAE detail is easy to miss. Cabinet Decision 109 exempts the financial free zones. That is why DIFC and ADGM appear as separate rows: they run their own beneficial ownership rules.
What this means
A group policy written to a single 25% standard will treat holders of 20% to 25% in Qatar and Mauritius as outside scope, when those jurisdictions’ own rules count them as beneficial owners.
The register is also not the answer on its own. Qatar’s guidance says so directly: supervised entities must not rely exclusively on the beneficial ownership information made available to them. Of the rules we could confirm, Qatar’s is the only one that gives financial institutions and DNFBPs a stated right of access, and only for CDD. Elsewhere, the customer’s own declaration and your own verification carry the file.
Three things worth doing this week
- Set your threshold per jurisdiction, not per group. If your policy says 25% everywhere, add exceptions at 20% for Qatar and Mauritius, and check the Banking Act figure for Mauritian financial institutions.
- Write down where each beneficial owner record came from. Customer declaration, register extract, or independent document. An examiner will ask.
- Use the local update window as your trigger. Fifteen days in the UAE and ADGM, thirty days in the DIFC, and thirty days from receiving the documents in Qatar. Ask corporate clients to tell you on the same clock.
Sources
This article draws on the following sources. Follow the links for the original text.
- UAE Cabinet — Cabinet Decision No. (109) of 2023 on Regulating the Beneficial Owner Procedures (CBUAE Rulebook)
- ADGM — Beneficial Ownership and Control
- DIFC Authority — Private Company Non-Financial and Retail Handbook (March 2026)
- Saudi Ministry of Commerce — Minister approves the Beneficial Owner Rules (Arabic)
- Saudi Ministry of Commerce — Key benefits of the Ultimate Beneficial Owner Rules
- Qatar Ministry of Commerce and Industry — The Beneficial Owner
- Qatar Ministry of Commerce and Industry — Guidance on Beneficial Ownership (2022)
- Mauritius Corporate and Business Registration Department — Companies Act 2001 (updated May 2026)
- Mauritius Corporate and Business Registration Department — Companies (Beneficial Owner) (Percentage of Shares) Regulations 2019 (GN No. 237 of 2019)
- Mauritius Corporate and Business Registration Department — Companies (Beneficial Owner) (Percentage of Shares) Regulations 2019 (updated)
- OMPIC — Request for access to the public register of beneficial owners
across-the-six AML beginner compliance financial-crime jurisdiction-briefing six-jurisdictions