UAE Civil Litigation LawCabinet Resolution No. (132) of 2023 Concerning the Administrative Penalties Imposed on Violators of the Provisions of Cabinet Resolution No. (109) of 2023 Concerning the Regulation of Real Beneficiary Procedures

Article (1) Definitions In application of the provisions of this Resolution, the words and expressions set forth herein shall bear the meanings ascribed to them, unless the context otherwise requires: State : United Arab Emirates. Ministry : Ministry of Economy. Minister : Minister of Economy. Decree-Law : Federal Decree-Law No. (20) of 2018 Concerning Combating Money Laundering and the Financing of Terrorism and Illegal Organisations, as amended. Executive Regulations : Cabinet Resolution No. (10) of 2019 concerning the Executive Regulations of Federal Decree-Law No. (20) of 2018 Concerning Combating Money Laundering and the Financing of Terrorism and Illegal Organisations, as amended.

-- 1 of 15 --

Cabinet Resolution of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution of 2023 concerning the Regulation of Real Beneficiary Procedures 2 Registrar : The Competent Authority supervising the Register of commercial names of different establishments Registered in the State. Concerned Authorities : Competent Government Authorities implementing any of the provisions of the Law by Decree and the Executive Regulations. Real Beneficiary : The Natural person to whom ultimate ownership is transferred or who exercises ultimate control over the Legal Person directly or through a chain of ownership or control, or other indirect means. It also means the natural person on whose behalf transactions are conducted or who exercises ultimate effective control over a Legal Person, as specified in accordance with the text of Article (5) Cabinet Resolution No. (109) of 2023 referred to. Board Nominee Member : Any Natural Person acts pursuant to the directions, instructions, or will of another person, who shall be officially appointed or holds a position in Legal Person and is usually a representative of Shareholders, members, or any other interested party. Senior Management : Power of Legal Person in Decision-Making. Beneficiary Register : Private Real Beneficiary Register of Legal Person that includes all their real data. Partners or Shareholders : Private Partners or Shareholders Register of Legal Person that includes all their information. Written Notice : Official Notice sent to the Legal Person or their representative by legally available means.

Article (3) Administrative Penalties 1. Without prejudice to any penalty or procedure stipulated by the Law by Decree and other relevant legislation, the Registrar has the right to impose Administrative Penalties resulting from Violators of the provisions of Cabinet Resolution No. (109) of 2023 referred to, and in accordance with the Violations and penalties mentioned in the table attached to this resolution. 2. In addition to the penalty of the fine imposed on Violations committed for the third time mentioned in the table attached to this decision, the Registrar has the right to suspend the commercial licence and close the commercial store of the Violating Legal Person, provided that this suspension is removed after he pays the Violation fine and corrects it by fulfilling the necessary requirements regarding the Violation.

Article (8) of Cabinet Resolution 2

-- 5 of 15 --

Cabinet Resolution of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution of 2023 concerning the Regulation of Real Beneficiary Procedures 6 within (15) fifteen days from the date of the Notice to the Violator. No. (109) of 2023 referred to in the Real Beneficiary Register.

-- 6 of 15 --

Cabinet Resolution of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution of 2023 concerning the Regulation of Real Beneficiary Procedures 7 Cont. Table Attached to Cabinet Resolution No. (132) of 2023 Concerning the Administrative Penalties Imposed on Violators of the Provisions of Cabinet Resolution No. (109) of 2023 Concerning the Regulation of Real Beneficiary Procedures The Two Administrative Penalties Legal Ref. Cabinet Resolution No. (109) of 2023 Violation SN Third Time Second Time First Time (100,000) one hundred thousand AED, along with notifying the Legal Person to correct the Violation. (50,000) fifty thousand AED and a Notice to the Legal Person to correct the Violation within (30) thirty days from the date of the Violation. A Written Notice to the Legal Person to comply within (30) fifteen days from the date of the Notice.

Article (8/1) The Legal Person does not comply with updating a Real Beneficiary Register. 4

-- 7 of 15 --

Cabinet Resolution of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution of 2023 concerning the Regulation of Real Beneficiary Procedures 8 Cont. Table Attached to Cabinet Resolution No. (132) of 2023 Concerning the Administrative Penalties Imposed on Violators of the Provisions of Cabinet Resolution No. (109) of 2023 Concerning the Regulation of Real Beneficiary Procedures The Two Administrative Penalties Legal Ref. Cabinet Resolution No. (109) of 2023 Violation SN Third Time Second Time First Time (80,000) eighty thousand AED, along with notifying the Legal Person to correct the Violation. (40,000) forty thousand AED and a Notice to the Legal Person to correct the Violation within (15) fifteen days from the date of the Notice to the Violator. A Written Notice to the Legal Person to comply within (30) thirty days from the date of the Notice.

Article (9) Publication and Entry into Force This Resolution shall be published in the Official Gazette and shall enter into force as of the day following its publication date. Mohammed Bin Rashid Al Maktoum Prime Minister Issued by Us: On: 02 Jumada II 1445 A.H. Corresponding to: 15 December 2023 AD

-- 4 of 15 --

Cabinet Resolution of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution of 2023 concerning the Regulation of Real Beneficiary Procedures 5 Table Attached to Cabinet Resolution No. (132) of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution No. (109) of 2023 Concerning the Regulation of Real Beneficiary Procedures The Two Administrative Penalties Legal Ref. Cabinet Resolution No. (109) of 2023 Violation SN Third Time Second Time First Time (40,000) forty thousand AED, along with notifying the Legal Person to correct the Violation. (20,000) twenty thousand AED and a Notice to the Legal Person to correct the Violation within (15) fifteen days from the date of the Notice to the Violator. A Written Notice to the Legal Person to comply within (15) fifteen days from the date of the Notice. 132.

Article (10) The Legal Person does not comply with providing the data referred to in Article (10) of the aforementioned Cabinet Resolution No. (109) of 2023 related to the data of the Director or Board Nominee Member to the Registrar. 5 (100,000) one hundred thousand AED, along with notifying the (50,000) fifty thousand AED and a Notice to the Legal Person to correct the – Article (10) The Legal Person fails to create a Partners or Shareholders Register. 6

-- 8 of 15 --

Cabinet Resolution of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution of 2023 concerning the Regulation of Real Beneficiary Procedures 9 Legal Person to correct the Violation. Violation within (30) thirty days from the date of the Violation.

-- 9 of 15 --

Cabinet Resolution of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution of 2023 concerning the Regulation of Real Beneficiary Procedures 10 Cont. Table Attached to Cabinet Resolution No. (132) of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution No. (109) of 2023 concerning the Regulation of Real Beneficiary Procedures The two administrative penalties Legal Ref. Cabinet Resolution No. (109) of 2023 Violation SN Third Time Second Time First Time (30,000) thirty thousand AED, along with notifying the Legal Person to correct the Violation. (15,000) fifteen thousand AED and a Notice to the Legal Person to correct the Violation within (15) fifteen days from the date of the Violation. A Written Notice to the Legal Person to comply within (30) thirty days from the date of the Notice.

Article (11/2): Legal Person fails to provide any additional data requested by Registrar within (14) 10

-- 11 of 15 --

Cabinet Resolution of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution of 2023 concerning the Regulation of Real Beneficiary Procedures 12 correct the Violation. correct the Violation within (15) fifteen days from the date of the Violation. from the date of the Notice. fourteen days from the date of the request. (100,000) one hundred thousand AED, along with notifying the Legal Person to correct the Violation. (50,000) fifty thousand AED and a Notice to the Legal Person to correct the Violation within (30) thirty days from the date of the Violation. A Written Notice to the Legal Person to comply within (30) thirty days from the date of the Notice.

Article (11/6) The Legal Person fails to disclose when issuing shares or stakes in the names of persons or members of management to the Registrar 13

-- 13 of 15 --

Cabinet Resolution of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution of 2023 concerning the Regulation of Real Beneficiary Procedures 14 within (15) fifteen days from the date of issuing the shares or stakes. (10,000) ten thousand AED, along with notifying the Legal Person to correct the Violation. (5,000) five thousand AED and a Notice to the Legal Person to correct the Violation within (15) fifteen days from the date of the Violation. A Written Notice to the Legal Person to comply within (30) thirty days from the date of the Notice.

Article (15) The Legal Person fails to disclose the classes of the Real Beneficiary in Complex Structures. 11

-- 12 of 15 --

Cabinet Resolution of 2023 Concerning the Administrative Penalties imposed on Violators of the provisions of Cabinet Resolution of 2023 concerning the Regulation of Real Beneficiary Procedures 13 The Two Administrative Penalties Legal Ref. Cabinet Resolution No. (109) of 2023 Violation SN Third Time Second Time First Time (20,000) twenty thousand AED, along with notifying the Legal Person to correct the Violation. (10,000) ten thousand AED and a Notice to the Legal Person to correct the Violation within (15) fifteen days from the date of the Violation. A Written Notice to the Legal Person to comply within (30) thirty days from the date of the Notice.