RAK ICC Sanctions Declaration & Close Persons Form

If you are setting up a RAK International Corporate Centre (RAK ICC) company, the RAK ICC sanctions declaration is one of the first documents you will be asked to sign. It is a short but consequential form (Ref ICC-049) that puts the entire responsibility for sanctions compliance on the applicant: you confirm, in writing, that the proposed company and everyone connected to it is clear of financial and economic sanctions. Get it wrong — or let the facts change without telling the registry — and RAK ICC can strike your company off with immediate effect. This guide walks through every clause, explains who is bound, and shows how our UAE company incorporation and AML compliance teams complete it cleanly the first time.

What is the RAK ICC sanctions declaration?

The RAK ICC sanctions declaration is a mandatory know-your-customer (KYC) and screening document that forms part of the incorporation pack for every RAK ICC company. RAK ICC is the offshore/international company registry in Ras Al Khaimah that issues International Business Companies (IBCs) — entities typically used for holding, international trade and asset structuring rather than trading inside the UAE. Because those structures can be attractive to sanctioned parties, the registry requires each applicant to sign the sanctions declaration and close persons form before the company can be registered.

The form does three things at once. First, it is a positive confirmation: you state that neither the proposed company nor any related party is a sanctions target. Second, it is a binding undertaking: you commit that no sanctions target will run, own, control or benefit from the company going forward. Third, it is an acknowledgement of consequences: you accept that RAK ICC may strike the company off with immediate effect if you breach any condition. In substance it transfers the day-to-day sanctions risk from the registry to the beneficial owners of the company.

Who must sign the RAK ICC sanctions declaration and close persons form?

The declaration is signed and dated by an authorised person of the proposed company — usually a proposed director, the beneficial owner, or the registered agent acting on the applicant's instructions. But the signature is only the visible part. What the authorised person is actually confirming is a statement about every related party of the company, so the real work is identifying and screening all of those people before anyone signs.

"Related party" is defined broadly on the form. It captures the proposed company itself and each of its shareholders, beneficial owners, controllers, directors and senior managers. Where the company is owned through a trust, it also captures the trustees, founders, grantors, settlors and beneficiaries of that trust. In other words, you cannot sign the form honestly until you have mapped the full ownership and control chain up to the ultimate human beings behind it.

Who counts as a "related party" under the RAK ICC sanctions policy?

Because the declaration stands or falls on the related-party definition, it is worth breaking down exactly who must be screened and why. The table below maps each category the form covers and the reason RAK ICC insists on it.

The common thread is that RAK ICC is not only interested in who legally owns the shares. It wants comfort over ownership, control and benefit right up to the ultimate beneficial owner. That is why identifying UBOs correctly — the same discipline required across offshore and mainland company formation in the UAE — is the foundation of a clean declaration.

Which sanctions authorities and lists does RAK ICC screen against?

The declaration is explicit about the sources it relies on. A "listed person" is anyone named as a target of financial or economic sanctions by the United Arab Emirates, the United Nations, the United States, the European Union, the United Kingdom, or other relevant sanctions authorities. Screening a related party against only one of these lists is not enough — the confirmation covers all of them.

Critically, the declaration goes beyond named individuals. You must also confirm that no related party is 50% or more owned or controlled by one or more listed persons, and that none is owned or controlled by, or acting as agent of, the governments of Cuba, Iran, North Korea or Venezuela. The Venezuela wording is unusually wide: it expressly reaches the state and government of Venezuela, its political subdivisions and instrumentalities including the Central Bank of Venezuela and Petróleos de Venezuela, S.A. (PdVSA), anyone they own or control, and anyone acting for the Maduro regime.

Which are the sanctioned territories you must declare against?

Separate from named persons, the declaration lists specific sanctioned territories. You confirm that neither the company nor any related party is resident or located in, operating from, or incorporated under the laws of these places — and that the company will have no registered office, branch, subsidiary, address or principal place of business there.

The form also closes an obvious loophole: business "with, through or involving" RAK ICC must not involve sanctions targets even indirectly — the example given is goods procured from, or transhipped through, a sanctioned territory. So a supply chain that merely routes through one of these places can put you in breach even if no owner is a listed person.

What does the "close persons" section require?

The "close persons" part of the form deals with the grey area: a related party who is not themselves a listed person but is a spouse, parent, grandparent, child, grandchild, relative or business partner of one. A family or business link does not automatically disqualify you — but it triggers four additional confirmations you must be able to stand behind.

1. Funds condition — either no funds were transferred to the related party (directly or indirectly) from the listed person, or any such funds were transferred before sanctions were imposed on that person.
2. Holding condition — no funds are, or will be, held by the company or the related party on behalf of or for the benefit of the listed person under any formal or informal arrangement.
3. Dealings condition — the company and the related party will have no commercial, economic or business dealings with the listed person.
4. Control condition — the listed person will have no ownership, control or influence over the company.

These conditions exist because sanctions can be evaded through relatives and partners. If you cannot honestly confirm all four, the connection is a genuine obstacle to incorporation — and one that is far better identified before you sign than discovered in a later review.

What happens if you breach the RAK ICC sanctions declaration?

The consequence is stated in plain language on the form: if you breach any of the conditions, RAK ICC has the right to strike the company off with immediate effect. There is no notice period built into that clause. Separately, the note at the end of the declaration reserves RAK ICC's right to strike off any entity that does not meet the RAK ICC sanctions policy.

A strike-off is not a paperwork inconvenience. It can dissolve the legal entity, freeze the ability to transact, and trigger the closure of associated bank accounts — and re-establishing a structure and re-onboarding with a bank can take months. The commercial damage of a sanctions-driven strike-off almost always dwarfs the cost of screening properly up front.

What is the 15-day change notification obligation?

The declaration is not "sign once and forget". If any of the facts in it change, the company is obliged to notify the RAK ICC Authority in writing within 15 days of the change. That includes a new shareholder or director, a change in ultimate beneficial ownership, a related party becoming connected to a listed person, or the business beginning to touch a sanctioned territory.

Because the 15-day clock is short and the trigger is any change, most owners find it far easier to route corporate changes through their registered agent, who can screen and file in one step rather than tracking the deadline in-house.

How does this connect to UAE AML/CFT law and your wider obligations?

The RAK ICC sanctions declaration does not sit in isolation — it is one expression of the UAE's anti-money-laundering and counter-terrorist-financing (AML/CFT) framework. That framework (Federal Decree-Law No. 20 of 2018 on Anti-Money Laundering and its implementing decisions) requires designated businesses and their agents to run sanctions screening, identify ultimate beneficial owners, assess risk and monitor customers on an ongoing basis. Corporate service providers who form entities like RAK ICC IBCs fall squarely within the population of DNFBPs (Designated Non-Financial Businesses and Professions) that must comply.

In practice that means the sanctions declaration should be backed by a wider compliance posture: goAML registration and AML policies, documented UBO records, and a monitoring process for the life of the company. Administrative penalties for AML/CFT contraventions in the UAE can be substantial — running to significant sums under the implementing decisions [VERIFY current AED range] — which is why treating sanctions screening as a checkbox rather than a control is a false economy. If your structure also creates a UAE tax footprint, the same beneficial-ownership clarity feeds into UAE Corporate Tax and, where relevant, a tax residency certificate application.

How to complete the RAK ICC sanctions declaration correctly

Completing the declaration cleanly is a repeatable, five-step process. Follow it in order and the signature at the end becomes a formality rather than a leap of faith.

1. Map every related party — list all shareholders, beneficial owners, controllers, directors and senior managers, plus any trustees, founders, settlors and beneficiaries for trust-owned structures.
2. Screen against all six authorities — check each person against the UAE, UN, US (OFAC), EU, UK and other relevant lists, and test the 50% ownership-or-control aggregation rule.
3. Confirm no sanctioned-territory nexus — verify no related party is resident, located, operating from or incorporated in Iran, North Korea, Cuba, Crimea or the four named Ukrainian oblasts, including through supply chains.
4. Complete the close persons conditions — where any related party is connected to a listed person, satisfy all four conditions on funds, holding, dealings and control.
5. Sign, retain and monitor — have an authorised person sign and date the form, keep the screening evidence, and notify RAK ICC within 15 days of any change.

This is precisely the workflow our team runs as part of a RAK ICC company incorporation engagement — so the declaration, the UBO file and the AML policy are all consistent and audit-ready from day one.

Common mistakes on the sanctions declaration and close persons form

Most problems come from the same handful of avoidable errors. The comparison below contrasts a clean, defensible application with the red-flag version that invites rejection or a later strike-off.

The pattern is clear: the failures are almost always about depth (stopping at the visible owner instead of the UBO), breadth (checking one list instead of all), and maintenance (no plan for the 15-day rule). Fix those three and the declaration holds.