Beneficial Ownership
and Control

The definition of a beneficial owner, in relation to a company or limited liability partnership (LLP), provides for a two-fold test for identifying a beneficial owner, which is as follows:

1. Any person:
   a. who has 25% or more direct or indirect ownership or voting rights in the company or LLP;
   b. irrespective of whether a natural person is identified under subparagraph (a) above, any natural person who controls the company or LLP; or
2. If no one is identified under paragraph 1. above, any person who holds the position of officer of the company or LLP (only applies if no beneficial owner is identified under tests 1.a) or b)).

The Regulations also provide for a definition of beneficial owner in relation to partnerships (other than an LLP), trusts and foundations.

• All applicable entities are required to maintain up to date beneficial ownership records and report changes to the Registrar within 15 days of a change.

• Failure to comply with respective provisions of the regulations is subject to maximum of a Level 7 fine ($25,000).

• The Record of Beneficial Owners is not published publicly for privacy reasons.
• Access to the Record of Beneficial Owners is limited to designated personnel of ADGM Registration Authority only.
• The Registrar may only disclose beneficial ownership information to third parties in accordance with the requirements of section 967 of the Companies Regulations or on the consent of the legal entity to whom the information relates.