Anti-money-laundering and client identification

Company formation and corporate services are regulated activities in the United Arab Emirates. Ouroboros Consulting FZCO carries client identification, monitoring and record-keeping duties, and applies them to every engagement.

What we ask for, and why

• Identity. Passport, proof of address, and Emirates ID where you are a UAE resident.
• Beneficial ownership. The natural people who ultimately own or control the company, not only the names on the shareholder register. A corporate shareholder means tracing the chain to individuals.
• Purpose and activity. What the company will do, who it will sell to and where the counterparties are.
• Source of funds and source of wealth. Where the money being used comes from, and how the wealth behind it was built. These are different questions and both are asked.

Checks we run

Sanctions and politically exposed person screening on the individuals involved, and a risk assessment covering the activity, the jurisdictions and the ownership structure. Higher risk means more documentation, not automatic refusal.

Ongoing obligations

• Records are kept for the period UAE rules require, after the relationship ends.
• Ownership changes must be told to us and to the authority. Beneficial ownership registers are kept current, not filed once.
• We re-check identification periodically and when circumstances change.

What we will not do

We decline engagements where identity or beneficial ownership cannot be established, where the source of funds cannot be explained, or where the purpose appears to be concealment rather than business. We also decline where a required regulatory approval is plainly unobtainable.

In some circumstances the law requires a report to the authorities and prohibits telling the client that one has been made. Where that applies, we simply do not proceed and do not explain further. That is a legal constraint, not a commercial choice.

Regulated activities

Some licence activities require approval from a named UAE authority before or after the licence is issued. We identify those during the enquiry and tell you which body must approve, so that a licence is not issued against an activity that cannot lawfully be carried out.

Questions

Compliance questions go to hello@yourfirm.ai. The designated compliance officer of Ouroboros Consulting FZCO is Sigitas Zivoltas.