How to prove your business activity to a bank in the UAE if your company operates remotely

Many entrepreneurs in the UAE whose companies provide digital services conduct meetings with clients and partners online and lack employees or physical offices. They believe that conducting their business remotely is acceptable to most local banks. However, since 2021, following the introduction of the Central Bank of the UAE Rulebook and the Financial Action Task Force (FATF) to assess the actual economic activity of each client, banks are treating online companies with greater caution and blocking their accounts more frequently.

In 2023–2024, UAE banks closed over 26,000 corporate accounts – 80% of which were due to insufficient evidence of economic activity. Companies without staff, physical offices, or clear processes are prime candidates for enhanced due diligence and inclusion in the high-risk category. The Dubai office of the international law firm Antwort Law has been helping UAE companies with remote management or online businesses successfully pass all banking compliance procedures for over three years.

What do banks want from their corporate clients:

• A real business model,
• Source of Income (SOF),
• Source of Owner Wealth (SOW),
• Substance (proof of genuine management and operations).

If a company lacks an office, physical employees in the country, or a well-defined infrastructure, and uses complex transaction structures, the risk of using such a company as a transit entity is higher, according to banks. Therefore, an online company requires more documentation than a traditional offline company. Furthermore, in the UAE, it is quite common to set up a company solely for visas or other purposes unrelated to actual operations.

We have compiled six key, non-obvious mistakes made by remote companies:

1) The country has an automated monitoring system that checks a company's "digital footprint": whether it has a website, social media, various platforms, online mentions, or advertising for its services or products. The absence of a digital footprint is a clear red flag for any financial institution.

2) Many digital companies fail to clearly explain their operating procedures in detail and in legal language.

3) There are no or very few contracts that the bank can verify the legality of transactions. Consequently, there are no invoices or confirmations of services rendered, and we know the main rule of banking: any transaction without explanation = risk.

4) No or very few expenses – this looks very suspicious, reminiscent of a transit structure.

5) Many entrepreneurs consider it normal to pay themselves from a corporate account without explanation.

6) Finally, receiving large payments without contracts.

So how can you clearly prove to the bank that you are a reliable, active company, albeit operating remotely?

First of all, understand that this is a complex process. Organizing just one of these is not enough, as banks consider regular, explainable, and documented transactions, along with all other factors, to be proof of real economic activity. Antwort Law assists with preparing a comprehensive package of documents for any type of bank audit, which includes:

Key:

Business plan (in banking format)

Financial forecast

• Transaction map (cash flow explanation) - explanation of the movement of funds
• Description of services
• Pricing model
• Evidence of operational activity (platforms, CRM, workflows)

AML/KYC:

• Source of Funds (SOF) - source of funds
• Source of Wealth (SOW) - source of wealth / origin of capital
• Anti-Money Laundering Questionnaire
• KYC Documents (client identification documents)
• Corporate structure diagram (the bank must clearly understand who makes decisions about the company and where the management is physically located)

If management is unclear, the bank considers the company insufficiently transparent. Corporate:

• Board of Directors Resolutions
• Internal Policies and Regulations
• List of Suppliers + Supporting Documents
• List of Clients + Cooperation Confirmations
• Set of Agreements (with Clients and Subcontractors)

Additional:

• Confirmation of Marketing Activity
• Screenshots of Current/Active Projects

Entrust your banking needs to professionals. A refusal from one bank is reflected in the CBUAE system, and other banks see that the client has already been rejected, so preparation, especially for the first bank, is critical. Don't create a negative history for your business where it can be avoided. Digital companies are required to demonstrate real work. Those who prepare in advance have a smooth process. Those who react only after a blocking event lose weeks and money.

Want to pass a bank verification without blocking? Contact us, and we'll ensure your account remains stable and free from the risk of closure.

Lidia Ivanova

International lawyer
Antwort Law