What a UAE Bank Must Verify About Your Company
The bank is not being difficult. It is being audited. The Central Bank of the UAE publishes what a licensed bank has to identify and verify about a company before it opens an account, and almost every document on the bank’s request list traces back to one of those rules.
This guide quotes the Central Bank’s own rulebook, separates what the regulator requires from what each bank chooses, and says plainly where the published rules stop. Our business setup service prepares the corporate documents banks ask for; our guide to closing a company in Dubai covers the other end of the same paperwork. We are a document clearing company, not a bank or a financial adviser, and nothing here is advice about which bank or product to choose.
Where the requirements come from
Two layers. The law is Federal Decree-Law No. 20 of 2018 on anti-money laundering, with its implementing regulation, Cabinet Decision No. 10 of 2019. The operational detail sits in the Central Bank’s rulebook, which is public.
The section that governs companies is 3.3.3, Customer Due Diligence for Legal Persons, implementing Articles 8 and 9 of that Cabinet Decision. It is shown as effective 15 August 2021 and in force.
“Legal person” is the regulator’s term for a company. Rule 1 of that section states the starting condition: “it must be registered and based in the UAE to carry out transactions through a RHP.”
The five things the bank must record about the company
Step 1 of section 3.3.3 lists them:
| What the rulebook requires | What that means on your side |
|---|---|
| “The legal person’s name” | The name exactly as registered, including the legal-form suffix. |
| “The legal person’s legal form (e.g., limited liability company)” | LLC, sole establishment, branch, free zone company — it is a recorded field, not a detail. |
| “The address of the legal person’s main office or headquarters” | A real registered address. This is why a tenancy contract or Ejari often appears on a bank’s list. |
| “The legal person’s trade license” | A current licence. An expired one fails the first step of the file. |
| “The name of the legal person’s senior managing official” | A named individual the bank can identify, not a job title. |
Nothing on that list is unusual to a UAE company. What is worth knowing is that these are recorded fields in a regulated file, not a form the branch invented.
The 25 per cent rule, and the look-through
This is the part that surprises founders with layered ownership. Step 4 of the same section:
“RHP must identify every individual who owns 25% or more of the legal person customer.”
“Beneficial owners cannot be other legal persons.”
So where a holding company owns your company, the bank does not stop at the holding company. The rule requires it to look through “until it identifies all individuals owning at least 25% of its customer”.
And when nobody reaches the threshold:
“If no individual owns 25% of the legal person customer” — the bank must identify and run due diligence on the senior managing official instead.
Step 5 then requires the bank to understand “the customer’s ownership and control structure”: who owns it, who controls it, and how. A clean shareholding chart is not a courtesy. It is the thing being verified.
Who may act for the company
Step 3 covers the person in the branch or on the call. The bank needs a “valid authorization, such as the trade license and/or a letter from the legal person customer’s management on its letterhead”.
That is why a board resolution or an authorisation letter on company letterhead appears on nearly every bank’s list, even when the person attending is the owner.
Five years of copies
The rulebook requires the bank to take a “clear, readable photo or photocopy” of documents obtained during due diligence, and to “retain those documents for five years after the transaction.”
A practical consequence: a blurred photograph of a passport page or a licence is not a formality the bank is fussing over. The rule says readable.
What the rulebook says about the account-opening process itself
A separate section, Account Opening (C 1/2021, effective 26 February 2021, in force), sets expectations on the bank rather than the customer. Four of its rules are worth knowing before you walk in.
| Rule | What it says |
|---|---|
| 3.20 | Banks “should seek to have appropriate systems in place” aiming at opening an account within three business days where the applicant is low risk and the standard due-diligence documents satisfy them. |
| 3.21 | Banks must clearly and consistently disclose the documents required to open an account. |
| 3.22 | Opening an account does not permit any transaction “until the Licensed Financial Institution has undertaken all appropriate due diligence”. |
| 3.23 | Funds may be received before the account opens, but must be blocked until the opening requirements are met, and “Customer consent must be obtained in such cases.” |
| 3.24 | Banks must record every SME account-opening request across all channels — including requests that were rejected, and those pending for less or more than 30 days — share the register regularly with senior management, and make it available to the regulator on request. |
Rule 3.21 is the useful one to hold on to. You are entitled to a clear list of the documents required. And rule 3.20 is an expectation on the bank’s systems, for a low-risk applicant with satisfactory documents — not a deadline you can enforce.
Rule 3.24 is the quiet one. Rejected and long-pending SME requests are recorded and reported upwards. That is a published fact about how these decisions are supervised.
Why two banks ask for different documents
Because the rulebook sets what must be identified and verified, not which documents prove it. The regulator names the trade licence, the registered address, the legal form, the senior managing official and the individuals above 25 per cent. How a given bank evidences each of those — which certificates, which attestations, which proof of business activity — is the bank’s own policy, applied on a risk basis.
So the list differs, and the underlying questions do not.
What is not published anywhere official
- Any bank’s document list. Rule 3.21 requires each bank to disclose its own; the Central Bank does not publish a single list for all of them.
- Minimum balance or minimum turnover for a corporate account. Commercial terms, set by each bank.
- How long account opening takes. Rule 3.20 is an expectation on systems for low-risk applicants, not a published processing time.
- Any obligation on a bank to accept a customer. The account-opening section we read does not address rejecting or exiting a relationship.
- What counts as “low risk” for the purposes of rule 3.20.
- Whether a free zone or offshore company is treated differently. Section 3.3.3 states the company must be registered and based in the UAE; it does not set separate rules by zone.
- A published appeal route if an application is declined.
- Which activities banks treat as high risk as a published list applying to all of them.
Our advice — practical guidance, not a rule
Marked as advice because no official page prescribes it.
- Ask for the document list in writing before you start. Rule 3.21 requires the bank to disclose it clearly and consistently, so asking is not an imposition.
- Draw the ownership chart down to named individuals. The rule is 25 per cent, through any layers, and ending at people. Prepare it that way and you have answered Steps 4 and 5 at once.
- Name the senior managing official before the bank asks. It is a required field in every corporate file, with or without a 25 per cent owner.
- Check the licence expiry date first. A current trade licence is one of the five recorded items, and a renewal mid-application restarts paperwork.
- Make every scan readable. The rulebook says a clear, readable photo or photocopy, kept for five years.
- Keep the registered address and the licence consistent. The address of the main office is a recorded field, and a mismatch with the licence is a question the file has to answer.
- Do not move money in before the account is open unless you have agreed it. Rule 3.23 allows funds to be received, but they are blocked until the requirements are met, and your consent is required.
If you would rather have the corporate documents assembled and attested before you approach a bank, our business setup desk prepares them and says plainly which items are regulatory requirements and which are a particular bank’s policy. Fees are quoted on request. We do not open accounts, introduce banks or advise on banking products.
Frequently asked questions
What does a UAE bank need to open a company account?
The Central Bank’s rulebook requires the bank to record the company’s name, legal form, main office or headquarters address, trade licence and the name of its senior managing official, to identify every individual owning 25 per cent or more, and to understand the ownership and control structure. The specific documents that prove those things are each bank’s own disclosed list.
Why does the bank want to know who owns the shareholder company?
Because the rulebook says “Beneficial owners cannot be other legal persons”, and requires the bank to look through corporate layers until it identifies all individuals owning at least 25 per cent of its customer.
What if no shareholder owns 25 per cent?
The rulebook says that if no individual owns 25 per cent, the bank must identify and conduct due diligence on the senior managing official instead.
How long does it take to open a business bank account in the UAE?
No processing time is published. Rule 3.20 says banks should seek to have systems in place aiming at opening within three business days where the applicant is low risk and the standard due-diligence documents satisfy them.
Is the bank allowed to ask for all this?
The requirements come from Federal Decree-Law No. 20 of 2018 and Cabinet Decision No. 10 of 2019, with the operational detail in the Central Bank’s rulebook. Section 3.3.3 is shown as implementing Articles 8 and 9 of that Cabinet Decision.
Must the bank tell me what documents it needs?
Rule 3.21 of the account-opening section requires licensed financial institutions to clearly and consistently disclose the documents required to open an account.
Can I transfer money in before the account is open?
Rule 3.23 permits funds to be received before opening, but requires them to be blocked until the opening requirements, including financial crime compliance, are met, and states that customer consent must be obtained in such cases.
How long does the bank keep copies of my documents?
The rulebook requires a clear, readable photo or photocopy of documents obtained during due diligence, retained for five years after the transaction.
Does my company have to be registered in the UAE?
Rule 1 of section 3.3.3 states that the legal person “must be registered and based in the UAE to carry out transactions through a RHP”.
Is there a minimum balance for a corporate account?
Not one published by the Central Bank in the sections we read. Minimum balances and turnover requirements are commercial terms set by each bank.