Most companies meet anti-money laundering law in two ways: as customers of banks that must know who owns and controls them, and, in some sectors, as regulated businesses with their own due diligence and reporting duties. Every company should keep beneficial ownership information accurate and filed on time; businesses such as dealers in high-value goods, real estate agents and corporate service providers carry full obligations. The EU will move to a single directly applicable rulebook from July 2027, and the US has narrowed beneficial ownership reporting to foreign companies.
Beneficial ownership duties for every company
In Germany, private-law legal entities and registered partnerships must obtain, keep up to date and report their beneficial owners to the Transparency Register without delay. UAE companies must keep a register of beneficial owners and file any change with the registrar within 15 days. In the United States the position changed in 2025 and 2026: FinCEN's final rule, effective 14 August 2026, permanently exempts US companies from beneficial ownership reporting, while foreign companies registered to do business in a US state must still report their foreign individual beneficial owners.
These filings matter beyond compliance. Banks check them when opening and reviewing accounts, and inconsistencies between registers and onboarding documents are a common cause of delays.1234
Businesses with full AML obligations
Some non-financial businesses carry the same duties as banks. In the UK, businesses in sectors covered by the Money Laundering Regulations that are not supervised by the FCA or a professional body, such as trust or company service providers, high value dealers and estate agents, must register with HMRC. The UAE's Federal Decree-Law No. 10 of 2025 and its executive regulations designate real estate brokers, dealers in precious metals and stones, lawyers, accountants and corporate service providers, among others, and require suspicious transaction reports to the Financial Intelligence Unit immediately, regardless of value. India's PMLA covers banks, financial institutions and designated businesses such as real estate agents and dealers in high-value goods.
In the EU, Regulation (EU) 2024/1624 will replace national transpositions of the AML directives with a single directly applicable rulebook; EUR-Lex records 10 July 2027 as its date of effect.5678910
| Market | Rule | Who it applies to | Figure or deadline | Source |
|---|---|---|---|---|
| Germany | Money Laundering Act s20 | Legal entities and registered partnerships | Report beneficial owners without delay | gesetze-im-internet.de |
| UAE (mainland and non-financial free zones) | Cabinet Resolution No. 109 of 2023 | Companies | File changes within 15 days | uaelegislation.gov.ae |
| United States (federal) | FinCEN BOI final rule | Foreign companies registered in a US state; US companies exempt | Effective 14 August 2026 | fincen.gov |
| United Kingdom | Money Laundering Regulations | Unsupervised regulated sectors (TCSPs, high value dealers, estate agents) | Register with HMRC before trading (some) | GOV.UK |
| UAE (federal) | Decree-Law No. 10 of 2025 | Financial institutions and DNFBPs | STRs immediately, regardless of value | Ministry of Economy and Tourism |
| India (central) | PMLA 2002 | Banks, financial institutions, designated businesses | Reporting entities registered with FIU-IND | FIU-IND |
| European Union | Regulation (EU) 2024/1624 | Obliged entities | Effective 10 July 2027 | EUR-Lex |
Decisions to make
- Is any group company in a regulated sector, such as dealing in high-value goods, real estate or corporate services?579Those businesses carry full due diligence, reporting and, in the UK, registration duties.
- Are beneficial ownership filings complete and consistent across Germany, the UAE and the US?124Germany requires reporting without delay, the UAE within 15 days of a change, and foreign companies registered in US states must still report to FinCEN.
- Will EU group companies be obliged entities after July 2027?10The new EU regulation applies directly and will replace national rules.
Documents usually needed
- Group ownership chart to natural persons, updated on every change
- Beneficial ownership filings and confirmations in each register
- AML risk assessment, policies and procedures for any regulated business
- Customer due diligence files and screening records
- Suspicious activity reporting log and training records
Common mistakes
- Filing beneficial ownership at incorporation and not updating it after share transfers
- Assuming a US company must still file BOI reports, or that a foreign company registered in a US state need not
- Missing that a trading business dealing in precious metals or stones is a regulated business in the UAE
- Tipping off a customer after filing a suspicious transaction report
- Planning EU AML compliance around national laws that will be displaced in July 2027
Questions businesses ask
Does a US subsidiary of a foreign group still file beneficial ownership information with FinCEN?
Not if it is a US company: the August 2026 final rule exempts US companies. A foreign-formed entity registered to do business in a US state must still report its foreign individual beneficial owners.34
How fast must a UAE company report a change of beneficial owner?
Within 15 days of the change, to the registrar.2
What this guide does not yet confirm
These points need checking with a qualified local professional before you rely on them.
- The operative provisions of Regulation (EU) 2024/1624 could not yet be checked; only its title and date of effect were confirmed.
- UK persons with significant control rules and Companies House identity verification are covered in the UK market guide, not here.
- Saudi and Singapore AML obligations for non-financial businesses were not compared.
- Penalties for late beneficial ownership filings in Germany and the UAE were not confirmed.
Sources and review status
Each statement is numbered to the source it was checked against. We use official sources where we can, and each statement says whether it was checked against an official or a secondary source. Sources last checked on 19 October 2026. None of it has been professionally reviewed yet: it is research checked against official and secondary sources by WONE Global, not legal or tax advice.
Legal entities under private law and registered partnerships must obtain, keep up to date and report details of their beneficial owners electronically to the registry authority for the Transparency Register without delay. Applies to German companies (including GmbH and UG) and registered partnerships; certain foreign entities are also covered (see de-regulatory-003).
§ 20 Abs. 2 as displayed contains no notification fiction (Mitteilungsfiktion); an active report is required.
Companies must keep a register of beneficial owners and submit any change in beneficial ownership information to the registrar within 15 days of the change. Entities covered by Cabinet Resolution No. 109 of 2023. Administrative penalties for breaches are set by Cabinet Resolution No. 132 of 2023 (not reviewed here).
FinCEN's final beneficial ownership information (BOI) rule, effective 14 August 2026, permanently exempts US companies from BOI reporting and removes the need to report US persons as beneficial owners. Federal rule under the Corporate Transparency Act. Applies nationwide; makes permanent the exemptions first introduced by the interim final rule of 26 March 2025.
Final rule published in the Federal Register on 14 August 2026 (document 2026-16576); the Federal Register page was seen in search results but not yet checked.
Foreign reporting companies must still report beneficial ownership information to FinCEN for their foreign individual beneficial owners. Foreign reporting company: an entity formed under foreign law that has registered to do business in a US state or tribal jurisdiction. US person beneficial owners are not reported.
Businesses in sectors covered by the Money Laundering Regulations that are not supervised by the FCA or a professional body, such as trust or company service providers, high value dealers and estate agents, must register with HMRC and must not trade without registering. Money service businesses and trust or company service providers must wait for confirmation of registration; other businesses can trade while the application is processed.
The federal anti-money laundering and counter-terrorist and proliferation financing law is Federal Decree-Law No. 10 of 2025, with executive regulations in Cabinet Resolution No. 134 of 2025. Federal.
The law text could not yet be checked (server error), so its repeal clause and effective date were not confirmed.
Designated non-financial businesses and professions under the AML executive regulations include commercial gaming operators, real estate brokers and agents, dealers in precious metals and stones, lawyers, notaries, other independent legal professionals and independent accountants, and company and trust service providers. Federal; supervisory authorities may designate further categories.
Reporting entities must file suspicious transaction reports with the Financial Intelligence Unit immediately and without delay, regardless of the transaction value. Federal; lawyers, notaries, other independent legal professionals and independent auditors are exempt in certain circumstances covered by professional secrecy (Article 18(2)).
Reporting entities under the PMLA are banking companies, financial institutions, intermediaries and persons carrying on a designated business or profession, which include casino operators, real estate agents and dealers in precious metals, precious stones and other high value goods as notified by the Central Government. Sections 2(1)(wa) and 2(1)(sa), Prevention of Money-laundering Act 2002; the Central Government may designate further activities by notification. Central law.
FIU-IND's consolidated text; the latest amendment it references is Act 23 of 2019. Later amendments, if any, were not checked. The full list of notified designated businesses and professions was not checked.
Regulation (EU) 2024/1624 of 31 May 2024 on the prevention of the use of the financial system for money laundering or terrorist financing is a directly applicable EU regulation, and EUR-Lex records 10 July 2027 as its date of effect. EU-wide; it sets a single rulebook for obliged entities in place of national transpositions of the AML directives. The list of obliged entities, beneficial ownership thresholds and transitional rules could not yet be checked.
Only the title and metadata were readable on EUR-Lex.
Questions on this topic
10 statements on anti-money laundering obligations for companies
