ADGM: corporate bank account opening

AML 8.3.2 requires the customer's name, legal form, incorporation details, registered and business addresses and governing documents. Verify the relevant particulars using reliable independent evidence. The UAE registry guide distinguishes ADGM Registration Authority records from mainland and other free-zone records.

Beneficial owners under AML 8.3.3

Identify individuals owning or controlling 25% or more of shares or voting rights, together with those exercising the other control specified in the rule. Obtain shareholder records for intermediate companies and agreements conferring appointment or management rights. Use the senior-management fallback only when the preceding tests identify no individual.

Verify representatives and authority. Obtain the resolution or power of attorney naming account operators and any joint-signature restrictions.

Risk review and acceptance

Establish expected transactions, countries and funding. Obtain the loan, investment or commercial documents needed to explain unusual arrangements. AML 8.4 requires enhanced measures for higher-risk relationships, including source of funds, source of wealth and senior-management approval.

Complete verification before the relationship unless a permitted timing provision applies, documenting the basis and controls. Resolve sanctions findings and incomplete CDD under the applicable rules before allowing activity.

AML 8.6 requires transaction monitoring and periodic review of CDD and customer risk. Revisit the affected records after an ownership change, new signatory or unexplained change in payments.