Three Regulatory Updates International Business Owners Should Know in 2026

Three Regulatory Updates International Business Owners Should Know in 2026

New AML controls in the UAE, a beneficial ownership register in Switzerland, and proposed company-transparency reforms in Seychelles

Information current as at 5 August 2026 (Dubai).

Behind many compliance requests, an updated passport, a new ownership chart, evidence of source of funds or details about a company’s directors, there is usually a regulatory reason.

Over the past three months, authorities in the United Arab Emirates, Switzerland and Seychelles have announced or advanced important changes affecting company ownership, corporate records and anti-money laundering controls.

The details differ between jurisdictions, but the direction is consistent: authorities increasingly expect businesses to know and document who ultimately controls a company, why a structure exists and whether its records reflect the current reality.

Here are three developments international business owners should have on their radar.

1. UAE: the new AML framework is moving into active implementation

The UAE’s principal anti-money laundering framework was substantially renewed through Federal Decree-Law No. 10 of 2025 on Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing, which became effective on 14 October 2025. Its Executive Regulations, Cabinet Resolution No. 134 of 2025, became effective on 14 December 2025.

Although the legislation itself took effect in 2025, official activity during May and June 2026 shows that attention has now shifted to implementation and enforcement.

On 7 May 2026, the UAE Ministry of Economy and Tourism held specialist workshops explaining the substantive differences introduced by the new framework. The Ministry specifically highlighted:

• Stronger beneficial ownership requirements.
• Tighter oversight of virtual-asset activity.
• More emphasis on internal controls and suspicious-activity reporting.
• Stricter administrative consequences for non-compliance.

The workshops covered the designated non-financial sectors supervised by the Ministry, including real estate agents and brokers, dealers in precious metals and stones, accountants, auditors, and trust and corporate service providers.

The scale of regulatory supervision is also significant. Official figures published in June 2026 reported approximately 8,900 inspections of designated non-financial businesses and professions during 2025, with administrative penalties totalling AED 160.33 million. Beneficial ownership enquiries increased by 43.3%, while the number of legal persons recorded as lacking beneficial ownership information fell substantially compared with 2024.

What does this mean for clients?

Most individual clients and ordinary trading companies are not themselves regulated as AML-supervised businesses. They will nevertheless experience the effect of the changes through their banks, corporate service providers, accountants, property professionals and other regulated counterparties.

Clients should expect more detailed questions concerning:

• The natural person or persons who ultimately own or control the company.
• Each intermediate company in a multi-layered ownership structure.
• The purpose of the company and the reason for selecting its jurisdiction.
• The origin of the owner’s overall wealth.
• The specific origin of money used for an investment or transaction.
• Expected customers, suppliers, countries and transaction volumes.
• Payments made by or received from unrelated third parties.
• The use of cryptocurrencies, digital wallets or virtual-asset service providers.

The Ministry’s March 2026 guidance reinforces a risk-based approach. It expects regulated service providers to identify and verify customers and beneficial owners, understand the purpose and economic rationale of relationships, and apply more extensive checks where a customer, jurisdiction, ownership structure or transaction presents higher risk.

In practical terms, a UAE company owner should not wait until a bank-account review or annual company renewal to update their records. Changes to ownership, directors, business activity, expected payments, residence or source of income should be documented and communicated promptly.

What UAE business owners should prepare

A well-maintained compliance file should ordinarily include:

• A current group and ownership chart ending with the ultimate natural-person owners.
• Current identification and residential-address evidence for owners and directors.
• A clear description of the company’s actual activities.
• Contracts, invoices, financial statements or other evidence supporting expected transactions.
• Evidence explaining source of wealth and source of funds where relevant.
• Details of any nominee, agency, power-of-attorney or third-party payment arrangement.

The central message is that the UAE has moved beyond adopting new rules: it is increasingly testing whether ownership data and AML controls are accurate, current and effective.

2. Switzerland: a federal beneficial ownership register starts on 1 October 2026

On 12 June 2026, the Swiss Federal Council confirmed that the revised Anti-Money Laundering Act and the new Act on the Transparency of Legal Persons and the Identification of Beneficial Owners will enter into force on 1 October 2026.

The reforms will establish a central federal transparency register containing information on the natural persons who ultimately control covered legal entities. The revised AML legislation will also extend due-diligence requirements to certain higher-risk advisory activities, including specified services connected with real estate transactions and the establishment or structuring of legal entities.

The register will be maintained by the Swiss Federal Office of Justice, with a separate control unit responsible for checking whether the information is accurate, complete and current. It will not be a public, freely searchable company register. Access will be available through the legal channels provided to competent authorities and certain regulated persons.

Which companies may be affected?

The reporting obligation covers most Swiss legal persons, including:

• Aktiengesellschaften, or Swiss stock corporations.
• Gesellschaften mit beschränkter Haftung, or limited liability companies.
• Cooperatives.
• Certain collective investment entities.

Certain foreign legal persons may also be covered where they have a registered Swiss branch, are effectively managed in Switzerland or own or acquire real estate in Switzerland. Certain entities, including listed companies and specified publicly controlled or supervised entities, benefit from exclusions.

For the purposes of the register, a beneficial owner is always a natural person. A person will generally be considered to exercise control where they hold at least 25% of the capital or voting rights, directly or indirectly, or otherwise exercise control through contractual or other arrangements. Ownership must therefore be traced through holding companies, trusts and other intermediate structures until the controlling natural person or persons are identified.

What does this mean for Swiss company owners?

The obligation is not satisfied merely by copying the shareholder list. A company may need to examine:

• Indirect ownership through foreign companies.
• Voting agreements and shareholder arrangements.
• Joint or coordinated control by several people.
• Trust, fiduciary or nominee relationships.
• Rights allowing someone to influence important decisions despite holding fewer than 25% of the shares.
• Differences between legal ownership and actual economic control.

Affected companies will report through the Swiss EasyGov platform or, in specified circumstances, through the relevant cantonal commercial register. The law takes effect on 1 October 2026, when the applicable transition periods will begin. Companies should confirm their particular reporting deadline rather than assuming that every entity has the same filing date.

What Swiss companies should do now

Before October, companies should:

1. Identify every natural person who meets the ownership or control test.
2. Trace indirect ownership through each intermediate legal entity or arrangement.
3. Review shareholder agreements, voting rights and other control mechanisms.
4. Resolve inconsistencies between the share register, commercial-register information and internal ownership records.
5. Collect the required identifying information for each beneficial owner.
6. Decide who will be authorised to submit and maintain the company’s filing.
7. Prepare access to EasyGov where electronic reporting will be used.

For legitimate business owners, this is primarily a corporate housekeeping exercise. The greatest difficulty is likely to arise where ownership chains are outdated, nominee relationships are undocumented or the person exercising practical control is different from the registered shareholder.

3. Seychelles: proposed IBC and trust reforms would increase transparency

Seychelles is also advancing changes affecting International Business Companies and trusts.

On 8 July 2026, the Seychelles Cabinet approved proposed amendments intended to strengthen corporate and trust transparency ahead of the country’s next regional AML evaluation. The International Business Companies (Amendment) Bill, 2026 and the Trusts (Amendment) Bill, 2026 were published in the Official Gazette on 20 July and listed for first reading in the National Assembly on 28 July 2026.

Proposed changes for International Business Companies

The IBC Bill proposes three particularly relevant changes.

First, a newly incorporated IBC would be required to appoint its first director within 30 days of incorporation, instead of the existing nine-month period.

Second, an IBC’s register of directors would need to record whether a director or alternate director acts as a nominee. Where a nominee arrangement exists, the identity of the person giving instructions, the “nominator”, would also have to be recorded.

Third, the name and date of appointment of each current director would become available through the statutory access mechanisms proposed by the Bill. Under the Bill’s transitional provisions, companies would need to update nominee and nominator information by 31 December 2026, while the proposed current-director disclosure provisions would take effect on 1 January 2027.

Importantly, the proposal concerns information on current directors. It should not be described as creating a public register of shareholders or beneficial owners.

Proposed changes for trusts

The Trusts Bill would require trustees to maintain accurate and up-to-date information in the trust register.

It would also enable financial institutions and designated non-financial businesses and professions to request relevant trust records where needed to fulfil their AML obligations. A trustee providing information in good faith would receive protection against claims that the disclosure breached confidentiality or fiduciary duties.

A trustee would generally be expected to comply with a relevant AML request unless the request was ambiguous, disproportionate or unrelated to the requesting entity’s compliance obligations, in which case the trustee could seek directions from the court.

What does this mean for Seychelles company and trust clients?

Seychelles IBC owners should begin checking whether their records contain:

• The full name and appointment date of every current director.
• An accurate register of directors.
• The nominee status of any director or alternate director.
• Complete details of the person for whom a nominee director acts.
• Supporting documents explaining the nominee relationship.
• Consistent information across the registered agent’s file, board records and statutory registers.

Trustees and persons connected with Seychelles trusts should similarly verify that the trust register accurately identifies the relevant settlor, trustee, protector, beneficiaries or class of beneficiaries, and any person exercising ultimate control.

An important legal-status point

As at 5 August 2026, the official materials reviewed continued to describe these measures as Bills, and the National Assembly order paper recorded their first reading on 28 July. They should therefore be treated as proposed legislation rather than final law until the parliamentary process is completed and any Act and commencement provisions are officially published. The dates contained in the IBC Bill are proposed implementation dates and remain subject to enactment.

Nevertheless, affected companies should not wait for the final deadline before reviewing their records. The proposed requirements concern information that well-administered companies should already be able to produce.

What these three developments have in common

The UAE, Switzerland and Seychelles are at different stages of reform, but their direction is similar.

Authorities want reliable answers to four basic questions:

1. Who ultimately owns or controls the company?
2. Who is acting on behalf of someone else?
3. Why does the company or structure exist?
4. Can the information be verified quickly from current records?

This does not mean that international companies, holding structures, trusts or nominee arrangements are automatically problematic. These can all have legitimate commercial, investment, succession or governance purposes.

The risk arises when the legal documents, information held by the registered agent and actual operation of the structure do not match.

For international business owners, good compliance is increasingly becoming part of ordinary corporate administration. A company that keeps its ownership, director, activity and financial records current is generally better placed to complete banking reviews, renew its services and respond to regulatory enquiries without unnecessary delay.

A practical five-document checklist

International company owners should maintain, at minimum:

• An up-to-date ownership chart showing every intermediate entity and ultimate natural-person owner.
• A current director and officer register, including appointment and resignation dates.
• Documentation of nominee or fiduciary arrangements, identifying who gives instructions and why the arrangement exists.
• A clear business profile, explaining activities, markets, counterparties and expected payment flows.
• Supporting financial evidence, including source-of-funds and, where relevant, source-of-wealth documentation.

The global compliance trend is not simply toward more information. It is toward information that is accurate, consistent, current and capable of being independently verified.

Disclaimer: This article is provided for general information only and does not constitute legal, regulatory, tax or financial advice. Requirements depend on the relevant jurisdiction, entity type, activities and ownership structure. Proposed legislation may change before enactment.

Principal official references

• Federal Decree-Law No. 10 of 2025 Regarding Anti-Money Laundering, Combating the Financing of Terrorism and Proliferation Financing , UAE Government, issued 30 September 2025 and effective 14 October 2025.
• Ministry of Economy and Tourism organises three workshops to strengthen legislative compliance for DNFBPs , UAE Ministry of Economy and Tourism, 7 May 2026.
• UAE records strong AML/CFT/CPF performance in 2025 , Emirates News Agency, published June 2026.
• Federal Council brings new anti-money laundering rules into force , Swiss Federal Council, 12 June 2026.
• Swiss Transparency Register guidance , Swiss Federal Office of Justice, June–July 2026.
• International Business Companies (Amendment) Bill, 2026 , Republic of Seychelles Official Gazette, 20 July 2026.
• Trusts (Amendment) Bill, 2026 , Republic of Seychelles Official Gazette, 20 July 2026.
• Revised Order Paper for 28 July 2026 , National Assembly of Seychelles.