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3.2.2.1 EDD: Beneficial Ownership

Effective from 27/9/2021

If the LFI has followed the steps described above and is still not confident that it has identified the individuals who truly own or control the customer, or when other high-risk factors are present, the LFI should consider intensifying its efforts to identify the beneficial owners. The most common method of doing so is to identify additional beneficial owners below the 25% ownership threshold mandated by UAE law. This may involve identifying and verifying the identity of beneficial owners at the 10% or even the 5% level, as risk warrants. It should also involve requiring the customer to provide the names of all individuals who own or control any share in the customer—without requiring them to undergo CDD—in order to conduct sanctions screening or negative news checks.