SITUATION:
The client, a citizen of country X included in international sanctions lists, approached us with the intention to establish a business in the UAE. At the time of contact the client had no commercial activity in the UAE — he only planned to register a company. Due to the sanctioned status of his citizenship, government registries and banks potentially regarded the client’s application as high-risk, which could lead to refusal of registration, refusal to open a bank account, and being flagged as a potential risk.
TASK:
Ensure a lawful possibility for the client to register a business in the UAE and to obtain all subsequent opportunities and corporate instruments available on the UAE market.
MAIN CLIENT ISSUES:
- sanctioned citizenship;
- absence of an international business portfolio;
- lack of financial/legal audits of the client’s income sources.
ACTIONS TAKEN:
1. Client due diligence
- An audit of the client’s income was conducted by our finance department: documentation of payments and their sources was structured, and the client’s spheres of activity were clearly articulated.
- An enhanced legal compliance review of the client was performed, which is our primary responsibility under UAE law.
- A compliance report was prepared.
- The client was screened in accordance with internal AML & KYC policy.
2. Findings and solution
- A set of documents and explanatory letters for the registrar and banks was compiled, confirming that the client does not conduct economic activity in country X, does not receive income from that country, and does not import goods/services from that region for conducting business in the UAE.
- Prepared and submitted: notarized client declarations, bank statements (from other jurisdictions), source-of-funds evidence, contracts/letters from potential counterparties in the UAE and abroad, and a positive opinion from the compliance officer regarding the client’s field of activity.
- All standard immigration programs for citizens of country X were closed; an exhaustive search for exclusive and legitimate citizenship programs in European countries and Atlantic island jurisdictions was conducted.
- Based on the comprehensive review, optimal programs were selected (economic citizenship / investor residence) that provide the fastest and lawful route to obtaining a second citizenship/residency while meeting all requirements of the new country.
- Full procedural support was organized: preparation of the documentation package, legal support, preparation of verification requests, and coordination with local legal and immigration operators.
RESULTS:
- After completion of the migration procedure and confirmation of the new citizenship/status, we submitted an application to register the business in a free zone that meets the client’s business activity requirements.
- An internal company policy for corporate governance was prepared.
- After registration, an investor visa for the client was obtained.
- A bank account was opened.
The client is successfully operating in the UAE.
