Opening a bank account in the UAE

The rules an application meets today are new. A federal decree-law on combating money laundering and the financing of terrorism and proliferation replaced the previous one in 2025, and the cabinet resolution carrying its executive regulations repealed the two decisions behind the earlier regime. Older checklists circulating online describe a framework that no longer applies.

The rest of our Emirates practice is on the Emirates page, and accounts in other jurisdictions under bank account opening.

What the regulations call a higher risk

The definition is written out, and much of it describes an ordinary foreign-owned company: customers from higher-risk countries, non-residents holding no State issued identity card, complex ownership structures, complex or economically unjustified transactions, large cash dealings and transactions with unknown third parties. The basic identification is fixed too: name, legal form, memorandum, tax registration number where corporate tax applies, address, articles and senior managers.

Landing inside that definition is no refusal. It changes the depth of the file, and that depth is described in the rules. It changes who has to be named: the chain runs to everyone holding twenty-five per cent or more, and to ten where risk warrants.

What the heavier file contains

• Additional information on identity and occupation, on the beneficial owner, on the amount of funds, and from public databases.
• More on why the relationship is wanted at all, and on the reasons behind transactions expected or already carried out.
• Reasonable measures to establish the source of funds and of wealth of the customer and the beneficial owner.
• More regular updating of the due diligence information held on both.
• A first payment made through an account in the customer's own name at a supervised institution.

The line an institution may not cross

Where the checks cannot be applied, the institution is prohibited from establishing or continuing the relationship or executing the transaction, and is to consider reporting the matter. Two absolute bars sit alongside it: no dealings with shell banks in any form, and no anonymous accounts or accounts under obviously fictitious names.

The figures the regulations name

What the rules do not give a company

The consumer framework covers natural persons and sole proprietorships, so a company gets neither a reason for a rejection nor the sixty days of notice before closure. The ombudsman unit does count a smaller company as a consumer, but turns a complaint away where the bank had under thirty complete business days to answer, or where the matter turns on its risk or money-laundering policies. The window is three years from the conduct, or two from learning of it.

After the account opens

Records, documents and data on transactions are kept for at least five years from the end of the relationship or the closure of the account. A transaction suspected of being linked to a crime can be suspended without notice for up to ten working days, and funds frozen for thirty days on the same basis.

Sources: the definition of a higher-risk customer, the enhanced measures, the prohibition, shell banks and anonymous accounts, the thresholds, retention and the freeze — articles 1, 7, 8, 12, 14, 15, 28, 37 and 51 of cabinet resolution 134 of 2025; the chain, consumer rules and complaint route — CBUAE CDD guidance 3.2.2 and 3.2.5, Consumer Protection Regulation, Ombudsman Unit Regulation.