By 
- Identify natural persons behind the ownership and control structure.
- The rules consider 25% ownership or voting rights and other forms of control.
- Confirm the applicable regime, records and filing process with your registrar.
What does UBO mean?
UBO means ultimate beneficial owner. Under the applicable federal rules, identification looks beyond the name on a share certificate to the natural person who ultimately owns or controls the company. The test includes 25% or more of ownership or voting rights, as well as control through other means.
First confirm which regime covers your company. Financial free zones and other excluded entities can have different requirements. Your registrar should provide the relevant forms and instructions.
Draw the ownership chain before completing forms
Start with the operating company and work upwards through any corporate shareholders. Record the ownership percentages and identify the people behind them. Separately note voting arrangements and rights that may create control. A simple diagram is often easier to review than several disconnected documents.
For example, if a holding company owns your business, naming only that holding company does not explain who ultimately controls it. Keep the supporting records that connect each level.
Prepare a usable record set
- An ownership and control chart with the basis for each conclusion.
- The identity and address information required for each relevant person.
- Supporting company documents for any corporate owner.
- A dated register and copies of submissions to the registrar.
- A named person responsible for keeping the information current.
What happens when ownership changes?
Build a check into share transfers, new investment and changes in control. Cabinet Decision No. 109 of 2023 includes requirements to update records and notify changes within prescribed periods, including a 15-day notification rule. Ask your registrar how the deadlines apply to the specific change; do not wait for annual renewal to investigate.
Keep the records secure and consistent
Store identity documents securely and share them through the receiving institution’s approved process. A bank may ask for ownership information during its own checks, but that does not replace the company’s registrar obligations. Compare both sets of information so that a historic ownership chart is not accidentally submitted as current.
For the underlying rules, read Cabinet Decision No. 109 of 2023 and confirm the current requirements with the relevant registrar.
