UAE Business Bank Account: Opening, KYC Reviews and What to Do If the Bank Freezes It
A corporate bank account in the UAE is opened, and kept open, on the strength of your documents. The bank has to know who owns the company, what it does and where its money comes from, and it re-checks all three for as long as the account exists. When a review or a block arrives, the way out is paperwork that ties each payment to a contract and an invoice.
Most of what founders read about opening a corporate bank account in the UAE is sales copy: rejection rates nobody can source, minimum-balance tables, lists of “easy” banks. We see the subject from the accounting side. A compliance team reads a file: the licence, the ownership chain, the turnover you declared, and whether the money moving through the account fits all of that. Clean records get an account opened faster and carry it through later reviews.
This guide covers what goes into that file, why the bank comes back for more later, and what to do, in order, when a KYC request or a block lands.
What KYC means for a company account
KYC (know your customer) is the process a bank uses to identify a customer, find the natural persons who ultimately own or control it, and understand what activity it should expect on the account. The law calls it customer due diligence, or CDD.
The legal base changed recently. Federal Decree-Law No. 10 of 2025 on anti-money laundering and combating the financing of terrorism and proliferation financing came into force on 14 October 2025 and repealed Federal Decree-Law No. 20 of 2018. Its Executive Regulations, Cabinet Resolution No. 134 of 2025, apply from 14 December 2025. Article 19 of the law requires banks to apply CDD and continuous monitoring, and Article 14 of the Regulations prohibits a bank from establishing or continuing a relationship when it cannot complete CDD. That second rule is why an unanswered KYC request so often ends in closure.
What the bank’s KYC file on your company contains
Articles 9 and 10 of the Executive Regulations list what the bank must collect and verify for a company:
- legal name, legal form, memorandum and articles of association;
- the corporate tax registration number, if the company is subject to corporate tax;
- registered office or principal place of business;
- the names of senior management, and proof that whoever acts for the company is authorised to;
- the beneficial owners: every natural person holding 25% or more of the shares or ownership interest, or, if nobody meets that test, whoever controls the company by other means, and failing that, the senior manager.
The Central Bank’s CDD guidance for licensed financial institutions (in force from 7 November 2025) adds the business profile: the purpose of the account, source of funds and source of wealth, your industry, the countries you will deal with, and the expected types and volumes of transactions. For higher-risk customers it also asks for anticipated turnover, known counterparties and seasonal patterns. That profile becomes the yardstick for everything the account does afterwards.
Your company keeps its own side of the record. Under Cabinet Decision No. 109 of 2023 it must hold a register of beneficial owners and update it within 15 days of learning of a change (the 2025 Regulations restate the duty in working days). Intentionally giving a bank false or misleading information about the beneficial owner is a crime under Article 35 of the 2025 law, punishable by imprisonment and a fine of at least AED 20,000.
If your company is itself in a regulated sector, such as a real-estate broker or a dealer in precious metals and stones, it has its own duties under the same law, and the bank will ask how you meet them.
How long should opening a business account take?
For a low-risk small or medium business with a complete file, the Central Bank now expects three business days, counted from the day the bank has every document it needs. The rule comes from the SME Customer Protection Regulation (C 2/2026), in force from 13 September 2026. The bank can set the deadline aside where its financial crime compliance requirements call for more work, so a higher-risk profile takes as long as the review takes.
The same regulation says that a delay on an accepted application for any other reason must be explained and cannot exceed two weeks. Money deposited during setup stays blocked until the checks are done, and the bank must tell you so in writing. A rejection comes with written reasons unless the reason relates to financial crime risk, and the bank must disclose its minimum document list for opening and for ongoing due diligence, so ask for it before you apply.
“SME” here follows Cabinet Resolution No. 22 of 2016, which sets headcount and revenue limits by sector (a services company is medium-sized up to 200 employees or AED 200 million of revenue). Larger companies fall outside the regulation.
Why banks run periodic KYC reviews
A KYC review is the bank checking that its file still describes you. The CBUAE guidance has banks review each customer on a schedule set by risk rating; its example is yearly for high risk, every two years for medium and every three for low, and it says those intervals are not mandatory. Each bank sets its own.
Reviews also follow events. The guidance lists triggers including:
- a change in ownership or in how the business operates;
- significant and unexplained changes in account activity;
- payments repeatedly rejected or blocked by correspondent banks;
- information the bank learns is outdated, such as an expired licence or a departed signatory;
- a match on a sanctions, PEP or negative-news screening list.
Underneath sits a comparison of expected and actual activity. Where they diverge, the guidance tells the bank to collect “a written explanation from the customer, supporting business documentation, or past financial statements”. It also flags vague source-of-funds answers such as “investment” or “self-funding” with no documents behind them, and new companies receiving large sums with no trading history. A company that doubled its turnover and never told the bank will draw questions even when every payment is legitimate.
Why won’t the bank tell me why my account is blocked?
Often it legally cannot. Article 25 of Federal Decree-Law No. 10 of 2025 makes it a crime to warn anyone, or disclose information, about transactions under review in connection with suspicious transaction reports, punishable by imprisonment and a fine of at least AED 50,000. The SME regulation likewise lets a bank withhold its reasons where they relate to financial crime compliance.
Compliance teams tend to say little about any review, so silence by itself tells you nothing about whether a report was filed. Answer the questions you have been asked as fully as you can.
Two different things get called a freeze. A bank can restrict or close an account under its own policy. Separately, the head of the UAE Financial Intelligence Unit can suspend a transaction for up to 10 working days or freeze funds for 30 days, with extensions decided by the Attorney General (Article 51 of the Executive Regulations). Under such an order, the bank must tell the owner which authority issued it and ask for documents proving the transaction and the source of funds are legitimate.
What to do when a KYC request arrives or the account is frozen
- Note the deadline and reply in writing before it. If you need more time, ask for it in writing.
- Ask the bank, in writing, to list what is outstanding: which documents and which transactions.
- For every flagged payment, send the contract, the invoice and proof of delivery, plus the matching entry in your books.
- Explain related-party money with its paperwork: the resolution behind a salary, the dividend resolution with the financial statements, the loan agreement with its repayment schedule. Our guide to paying yourself from a UAE company matches each payment to its document.
- Bring the bank’s file up to date: renewed licence, new activity, new shareholder or manager, new tenancy contract, updated beneficial-owner register.
- Keep a log of every exchange with dates, names, what you sent and reference numbers.
- If the bank stops responding or you disagree with the outcome, file a formal complaint with its complaints unit. Under the SME regulation the bank must acknowledge it within 2 business days and give a final written answer within 30 business days, including how to escalate.
- If that fails, take it to Sanadak, covered below.
If the bank decides to exit, the CBUAE guidance says the account should be closed “in a commercially reasonable manner”. We found no CBUAE rule fixing a notice period before a bank closes a business account, so read your account terms and keep a second account ready to receive the balance.
What the bank asks for, and what proves it
| What the bank asks about | What answers it |
|---|---|
| Source of share capital or first deposits | Personal bank statements showing the money, a sale contract for the asset sold, a dividend resolution from another company |
| A large incoming payment | Contract or purchase order, your invoice, delivery note or signed acceptance of the service |
| A payment to a supplier abroad | Supplier contract, their invoice, shipping documents for goods |
| Transfers to the owner or a relative | Employment contract and payroll record, dividend resolution with financial statements, or a written loan agreement |
| Round-sum transfers between related companies | Intercompany or loan agreement, board resolution, matching entries in both companies’ books |
| Turnover well above what you declared | Financial statements or management accounts, VAT returns for the period, the contracts behind the growth |
Can I complain to Sanadak about a frozen or closed account?
You can, and the grounds decide the outcome. Sanadak, the ombudsman unit set up by the Central Bank, handles complaints free of charge from individuals, sole proprietors and SMEs after the bank has had its chance to respond. It may reject a complaint that materially relates to a bank’s risk management or anti-money laundering policies and practices.
That exclusion catches most complaints about the closure decision itself. Service failures are on firmer ground: no response to a complete set of documents, an unexplained delay, fees charged against the rules, or a balance not paid out after closure.
Timing needs care. The 2023 regulation that created Sanadak lets it reject a complaint if the bank was not given 30 complete business days to respond, while the u.ae page on Sanadak currently says 15 calendar days. Check the live criteria on sanadak.gov.ae before filing. The outer limit is three years from the conduct or two years from when you became aware of it, whichever ends later, and Sanadak will not take a matter already before a court.
Keep the books and the bank file telling the same story
The bank now records your corporate tax registration number, so your tax filings and your bank profile describe the same company in places the bank can see. If the turnover you declared at opening, the figures in your VAT returns and the revenue in your corporate tax return point in different directions, the CBUAE guidance tells banks to escalate the discrepancies they cannot resolve.
Prevention is routine work. Issue an invoice for every receipt and file the contract behind it. Reconcile the bank statement monthly so a query can be answered from the ledger the same day. Pay the owner on documented terms. Tell the bank when the business changes, before its monitoring notices. Banks keep their records for at least five years after the relationship ends; our guide to record-keeping requirements covers how long the FTA expects you to keep yours.
Before you apply: an opening checklist
- A licence whose activities match what the company will really do (see our trade licence guide).
- MoA, AoA, shareholder register and beneficial-owner register.
- Passports and Emirates IDs of the signatories and of every 25% owner.
- Proof of the office address, such as the tenancy contract.
- A one-page profile: activity, expected monthly turnover, main countries, main customers and suppliers.
- First contracts or invoices, if you have them, and evidence of where the share capital comes from.
- Your corporate tax registration number, if the company is registered.
The full sequence from licence to visas to bank is in our guide on how to open a company in the UAE.
How QuickTax helps
We keep your books in the shape a compliance team asks for: receipts matched to invoices, contracts filed against payments, owner and related-party transfers documented, and turnover that agrees across the ledger, the VAT returns and the corporate tax return. When a KYC request or a block arrives, we help you build the response pack from those records.
See how our accounting service keeps your records bank-ready →
This material is for reference and is not legal advice. Banking and AML rules change; check current requirements with the Central Bank of the UAE, the CBUAE Rulebook and Sanadak.
What this means for you
A UAE business account depends on a file the bank keeps checking for as long as the account is open. Three things decide how that goes:
The bank has to finish its due diligence
Under Cabinet Resolution No. 134 of 2025 a bank may not open or keep an account when it cannot complete customer due diligence. An unanswered KYC request can end the relationship.
Answer reviews with documents
For each flagged payment, send the contract, the invoice and proof of delivery. Owner and related-party transfers need a resolution or a written loan agreement behind them.
Complain in the right order
Go to the bank complaints unit first: an SME gets an acknowledgement within 2 business days and a final answer within 30. Sanadak comes next, though it may reject complaints about a bank’s AML policies.
Frequently asked questions
How long does a UAE bank keep my company’s KYC records after the account is closed?
At least five years. Cabinet Resolution No. 134 of 2025 requires banks to keep customer due diligence records, account files, correspondence and copies of identity documents for no less than five years from the end of the relationship or the closure of the account, and to hand them to the authorities promptly on request.
What is the difference between source of funds and source of wealth?
Source of funds is where the money in a specific transaction or deposit came from, such as a customer payment or the sale of a property. Source of wealth is how the owner built their overall net worth, such as an earlier business or an inheritance. Banks ask for documents on both when they rate a customer as higher risk.
Does a free zone company have to keep a beneficial owner register?
Yes, if it is registered in a commercial free zone. Cabinet Decision No. 109 of 2023 applies to mainland companies and companies in commercial free zones, and requires each to keep a register of beneficial owners and update it within 15 days of a change. The financial free zones and wholly government-owned companies are exempt and follow their own rules.
Can my bank charge a fee for updating KYC documents or closing the account?
For SME customers, the CBUAE SME Customer Protection Regulation says banks must not charge fees for work done to meet legal requirements, such as updating identification documents. It also bans a closing fee or penalty once the account has been open for six months or more. Larger companies outside the SME definition are not covered by these rules.