About The Ministry

Obligations of Commercial Companies Regarding Anti-Money Laundering and Terrorism Financing Requirements

Legal Framework:

Obligation to Maintain Mandatory Registers:

Commercial companies are required to maintain the following mandatory registers:

  • Basic information register and all supporting documents
  • Beneficial Ownership Registry
  • Shareholders or partners register
  • The company must keep these registers in a manner that allows them to be made available to the competent authority upon request, either at the company’s headquarters or any other location notified to the management and the competent authority.
  • The company must ensure that all mandatory registers are kept up to date to reflect any changes or amendments to company data, ownership structure, directors, or other relevant information.

Appointment of a Natural Person Responsible for Providing Required Information:

  • Each commercial company must designate at least one natural person residing in the State of Qatar who is authorised to provide all information contained in the mandatory registers and to assist upon request.
  • The company’s legal representative must complete the Form for Appointment of Person Responsible for Providing Mandatory Records Information, sign it, and submit it with all required supporting documents to both the Companies Affairs Department and the Commercial Registration and Licenses Department at the Ministry of Commerce and Industry.
  • The appointment of this person does not exempt the legal representative of the company from responsibility. The company’s director or chairman of the board remains fully accountable before the competent authority for providing all required information and assistance.

For further details on commercial companies’ obligations in fulfilling AML/CFT requirements as per Article 18 bis of the Commercial Companies Law (added under Law No. 8 of 2021) and Decision of the Minister of Commerce and Industry No. (2) of 2022, refer to:

Commercial Companies Compliance Guide with AML/CFT Requirements.

Obligations Related to Beneficial Ownership

Definition of Beneficial Owner

A beneficial owner is the natural person who ultimately owns or controls a legal person or legal arrangement, or on whose behalf a transaction is conducted. It also includes a person who exercises ultimate and effective control over a legal person or legal arrangement.

Beneficial Ownership Declaration Requirement:

  • Under Law No. (1) of 2020 on the Unified Economic Register, and Decision of the Council of Ministers No. (12) of 2020 on the Implementing Regulations of the aforementioned Law, submission of a beneficial ownership declaration is mandatory for applying for a license, registration in the commercial register, amendment, or renewal with respect to legal persons and legal arrangements. No such application shall be accepted unless it is accompanied by the beneficial ownership declaration.
  • Every commercial company must identify its beneficial owner based on certified documents, information, or data when applying for registration, amendment, or renewal in the Commercial Register, and must keep this documentation up to date.

Identifying the Beneficial Owner:

The beneficial owner(s) of a commercial company are identified as follows:

  1. The natural person(s) who directly or indirectly own a controlling ownership interest of not less than 20% of the company’s capital or voting rights.
  2. In cases where it is not possible to determine the identity of the beneficial owner, or where there is doubt that the natural person holding a controlling ownership interest is in fact the beneficial owner under the preceding clause, or where no natural person exercises control through ownership interest or voting rights, the identity of the natural person (or persons) who exercises actual or legal control or influence, by any means whether direct or indirect, over the executive bodies, the general assembly of the company, or its operations, shall be verified. This includes determining the content of decisions adopted by the general assembly through voting rights he/she controls, or by virtue of his/her status as a partner or shareholder having the authority to appoint or remove the majority of the members of the company’s management, administrative, or supervisory bodies, or through other instruments of control or influence.
  3. Where no beneficial owner is identified under the above, the beneficial owner shall be deemed to be the natural person who holds the position of the company’s legal representative in accordance with the applicable legislation.

Maintaining the Beneficial Ownership Registry:

  • The Beneficial Ownership Registry contains the information that must be declared by commercial companies when applying for licensing, registration, amendment, or renewal, and must be kept up to date and supported by relevant supporting documents, in accordance with Law No. (1) of 2020 on the Unified Economic Register and its Executive Regulations. A copy of this register must be submitted to the Commercial Registration and Licenses Department within ten (10) days from the date of the application.
  • Companies must retain the Beneficial Ownership Registry for at least ten (10) years from the date of the company’s dissolution.

For further details on identifying and declaring beneficial ownership information, and maintaining a dedicated register, refer to:

Guidance on Beneficial Ownership.

Commercial Companies’ Obligations Relating to Beneficial Ownership.