Does your company need to maintain a register of UBOs and nominee directors?

The United Arab Emirates (UAE) recently issued Cabinet Resolution No. 58 of 2020 on the Regulation of the Procedures of the Real Beneficiary (the Resolution), which came into effect on 28 August 2020 and replaced Cabinet Resolution No. 34 of 2020 issued earlier this year.

Over the years, certain free zones in Dubai have already implemented requirements about information to be furnished regarding an Ultimate Beneficial Owner (UBO) during the registration process. However, many of the licensing authorities in the UAE previously did not require such information from the companies.

The new Resolution aims to introduce the requirement for a beneficial ownership register in the UAE mainland and unify the minimum disclosure requirements for corporate entities incorporated in the UAE mainland and in the non-financial free zones.

The Resolution addresses the disclosure requirements at the corporate registration stage, as well as the requirement to subsequently maintain a shareholder register, a register of beneficial owners and a register of nominee directors. Companies are now required to file the beneficial ownership information with the relevant Registrar by 27 October 2020.

Key points:

  • All companies in the UAE, both mainland and free zone companies, with the exception of companies incorporated in the financial free zones (Abu Dhabi Global Market (ADGM) and Dubai International Financial Centre (DIFC) and companies owned by the Federal Government and their subsidiaries), must now keep at their office premises:
    • A shareholder register
    • A register of beneficial owners
    • A register of nominee directors.
  • Companies must file such information relating to the shareholders and beneficial owners with the relevant registrar and licensing authorities responsible for supervising the register of trade names for the various types of establishments registered in the UAE (the Registrar) by 27 October 2020.
  • Companies must notify the Registrar of any change or amendment to the information provided within 15 days of such change or amendment. Also, the companies need to designate an Individual who can be contacted by the regulators regarding the matters enacted in the resolution.
  • Companies which are listed on well-regulated stock exchanges or companies which are owned by these listed companies may rely on the disclosures made to the relevant stock exchange rather than making independent inquiries as to the beneficial ownership.

The resolution has been adopted in furtherance of Federal Law no. 20 of 2018, on Anti- Money Laundering, which placed an obligation on corporate entities to disclose any individual ownership (whether beneficial or actual) in an entity which owns twenty five percent (25%) or more of the company, to the relevant regulator.

To understand more about how the above changes can affect your business, please reach out to us on

Affiniax Partners’ HR Rising Star

Best HR practices during Covid-19 Pandemic


I chose the Human Resources discipline for my MBA as I wanted to have a positive impact on people’s lives through the introduction of employee-friendly policies, influence future aspects of the company based on my recruitment decisions, and help organizations identify key talent.

My Ongoing HR Journey…

Oct 2017 – I began my HR career as an HR Faculty at National Academy, Dubai, where I delivered academic lectures on HR topics to working professionals. The lectures delivered were based on knowledge gained during my MBA, and I realized that I must gain practical HR working experience to enhance my knowledge regarding regional HR practices and UAE employment laws.

Dec 2017 – To further my career, I joined Affiniax Partners as an HR Executive. At Affiniax, management intended to transform the traditional operating model via fully integrated change management strategies and strategically managed HR transformation. It didn’t take me long to understand that the reasons why I chose HR as my career path were good to get started but not great to accomplish what I envisioned.

My vision was to align HR closely with Affiniax’s strategy in coordination with my colleagues and focused on enhancing the internal processes.

My first step was meetings with key employees and department heads regarding the company’s policies and processes. I presented those suggestions to the management, which resulted in decisions regarding proper SOP’s. I designed the Employee Manual with clear policies and processes in consultation with line managers and employees.

Soon after, I got selected for the Youth Leadership Program (YLP) at Affiniax in May 2018, which focused on the development of personal and professional skills. The selection was done based on interviews with the CEO and the training team.

I implemented the automation of manual tasks through migration to cloud-based services by ensuring process simplification and introduced a free HR software, Beneple (with limited features) with a pilot approach to familiarize the employees with cloud HR.

After successfully implementing Beneple, I implemented Zoho People in 2019 which consisted of more features. Again, I executed it successfully by overcoming challenges related to time taken to train the employees, altering the culture to adopt digital processes and to achieve 100% technology acceptance among the employees.

I revamped the performance management of my organization in 2018 through Robert Mosley’s “KPI & MSC model”. In 2019, I moved the same model onto the cloud for better record management, better security and multiple options of customizations in approval levels.

I chose a free software, Surveymonkey to evaluate ongoing learning programs at our workplace. I designed online forms, considering time spent by employees to evaluate the programs, ease of filling up the forms, better security and record-management.

I introduced employee surveys to measure the workplace climate and get a holistic perspective of employees.

I introduced comprehensive reports for Exit Interviews, Candidate selections, 360 Degree Reviews and Learning Evaluations.

Business Outcomes

  • Online L&D Evaluation and Performance Management – Data analysis and collection time reduced by 30%.
  • HR software – Reduction of time by 30% because of real-time attendance reports, customized online reports, better file management and digital record keeping.
  • Employee Surveys – 75% of the interns found the induction training session to be extremely useful and were very satisfied with our recruiting process.

Overcoming Challenges

The challenge was just around change as the employees were used to the rhythms of the old system. I strategically managed the change with the line managers by implementing phased rollouts of initiatives and training sessions.

Present Day
2020 is different now than it was a few months ago. With our workforce moving towards remote working, maintaining productivity, culture and employee engagement are extremely important. I conduct creative virtual team activities (definitely more than before), to build stronger relationships.

Moving Ahead
My CEO, after observing my passion, gave me the opportunity to showcase my skills for client assignments, which included Employee Manual and Agreements, Interview Assessment Reports, Succession Planning, Incentive structure, Organization Culture, to name a few. It was refreshing to experience this gradual shift towards consulting, where I got to enhance my knowledge with each assignment and share new perspectives that add value to my clients’ businesses.

I invest my time in reading leadership and HR books and networking at HR events to uncover the best practices of other organizations.