Pro Count

Sectors under AML supervision

AML Compliance for Corporate Service Providers

Those who form companies for others stand on the front line. Beneficial owner screening is the core of your work, not an addition to it.

A UAE corporate service provider checking beneficial ownership details

Corporate service providers occupy a distinctive position in the AML system: you create the entities that may later be used to obscure ownership or move funds. That is why you are treated as a first line of defence rather than a peripheral party.

Activities in scope typically include company formation, providing nominee director, shareholder or agent services, supplying a registered address, and similar arrangements — all of which place you between the client and the entity being created.

Corporate service provider AML compliance concentrates on a single question: who is the real natural person behind this request? Everything else is detail in service of that question.

What your business must do

Beneficial owner screening

Reaching the natural persons behind every corporate client through the ownership chain, rather than stopping at the direct shareholder.

Documenting nominee arrangements

Where you provide nominee director or shareholder services, both nominee and principal must be clearly documented.

Understanding the purpose of formation

Documenting the intended activity and the logic of the structure requested; an unexplained structure is itself an indicator.

Enhanced due diligence

Stronger measures for politically exposed persons and clients from higher-risk jurisdictions.

Ongoing monitoring

The client relationship continues after formation, and periodic refresh of their information is an obligation, not an option.

Registration and reporting

Registering on goAML and reporting where grounds for suspicion arise.

Risk indicators in this sector

  • Complex structures with no clear commercial rationale
  • A client who avoids or stalls on disclosing the beneficial owner
  • Requests for multi-layered nominee arrangements
  • Rapid formation of several entities for the same party
  • A client paying in cash and avoiding the banking route

Frequently asked questions

Are we in scope simply because we hold the licence?

Scope attaches to carrying out defined activities for clients, such as company formation and agency services. We assess your actual activities and confirm what applies.

What is our responsibility after handing the entity to the client?

An ongoing relationship requires monitoring and periodic refresh. Handover does not automatically end the obligation.

Can you run our framework and audit it?

No. If we take on your compliance function, we cannot audit it — independence is a condition of an independent audit.