In my previous article, I examined the growing regulatory focus on Ultimate Beneficial Ownership (UBO) and Source of Wealth/Source of Funds (SoW/SoF), highlighting the global shift toward deeper transparency. That shift is particularly visible across the Middle East and Africa (MEA), where ownership structures are often layered, family-driven, or state-linked.

Using legal entity data available through platforms such as Diligencia’s ClarifiedBy, we can clearly see that many of the region’s most prominent corporate groups have multiple ultimate beneficial owners. This is not unusual but it carries significant compliance implications.

Table of contents
The Middle East: Family capital and layered structures
Africa: State ownership, royal holdings, and extractives
Why multiple UBOs matter
Structural drivers of multiple UBOs
To sum up

The Middle East: Family capital and layered structures

Across the Gulf and wider Middle East, large conglomerates frequently originate from family enterprises that have evolved into diversified holding groups. Over time, ownership is distributed among siblings, branches of extended families, and intermediate holding vehicles.

ClarifiedBy entity data illustrates this pattern:

• Al-Futtaim Group (UAE) is owned by several members of the Al Futtaim family, meaning multiple individuals meet UBO thresholds.
• Olayan Group (Saudi Arabia) is structured through holding companies with multiple beneficial owners within the Olayan family.
• Alshaya Group (Kuwait) is controlled by family stakeholders, with several individuals holding significant ownership interests.
• Galfar Engineering & Contracting (Oman), though publicly listed, retains concentrated ownership among the Al Araimi and Ali families.

In each case, multiple individuals can meet the 25% ownership or control threshold commonly used in AML frameworks. Public listing does not eliminate UBO obligations; it often complicates the analysis.

The compliance challenge is not the presence of multiple UBOs but ensuring each qualifying individual is identified, verified, screened, and risk assessed independently. There is of course the added complexity of retrieving and interpreting authoritative information from official sources that may be fragmented, in an unfamiliar language, and governed by unfamiliar business and reporting cultures.

Africa: State ownership, royal holdings and extractives

Across Africa, ownership complexity takes several forms.

• Sonatrach (Algeria), a state-owned oil company, illustrates how multi-layered subsidiaries and joint ventures can create indirect ownership considerations.
• In Morocco, Al Mada is a major private holding company with significant investment activity, with the Moroccan Royal Family as major stakeholders.

In Nigeria’s oil and mining sectors, the Extractive Industries Transparency Initiative (EITI)¹ has repeatedly identified complex ownership arrangements, often involving three or more individuals holding significant (>25%) control. Given the sector’s historic corruption risk, UBO scrutiny is particularly acute.

Meanwhile, MTN Group (South Africa), though publicly listed, features large institutional and private shareholders that may trigger multiple UBO disclosures under South Africa’s FICA regulations.

Again, the pattern is clear: multiple UBOs are common, whether through family concentration, joint ventures, state participation, or institutional blocks.

Why multiple UBOs matter

Multiple beneficial owners increase regulatory and operational complexity:

• Each UBO must be individually identified, verified, and screened.
• Risk profiles may differ between owners.
• Source of Wealth assessments may be required for each qualifying individual.
• Control rights may not align precisely with shareholding percentages.
• Regulatory filings must accurately reflect all qualifying persons.

As noted in my earlier article, identifying ownership is only part of the equation. Wealth origin must also be understood and substantiated proportionately to risk. In multi-UBO structures, that obligation multiplies.

Entity intelligence tools such as Diligencia’s ClarifiedBy enhance visibility by mapping corporate hierarchies and beneficial ownership chains across jurisdictions. However, structured analysis and professional judgment remain essential.

Structural drivers of multiple UBOs

Across MEA, recurring structural themes explain why multiple UBOs are prevalent:

Family offices and conglomerates – Siblings or family branches frequently hold 25% or more each.
Private equity and joint ventures – Multiple investors, particularly in UAE free zones, meet ownership or control thresholds.
Holding company structures – Ownership chains often pass through intermediate entities owned by several individuals.
State and royal participation – Government or royal stakes introduce additional disclosure and PEP considerations.

To sum up

The Middle East and Africa demonstrate in practical terms what I argued previously: transparency around ultimate beneficial ownership and source of wealth/funds is foundational to financial integrity.

Family conglomerates, state-linked enterprises, joint ventures, and holding structures mean that multiple UBOs are often the norm rather than the exception. For firms operating in or onboarding clients from the region, the obligations are clear:

• Trace ownership through every layer.
• Identify every qualifying natural person.
• Assess each UBO individually.
• Substantiate wealth explanations where required.
• Document conclusions defensibly.

Complexity does not negate accountability. In an increasingly scrutinised global environment, robust UBO identification and wealth verification frameworks are essential for credible participation in regional and international markets.

Diligencia helps customers from around the world to find essential information on organisations registered in Africa and the wider Middle East, drawing on primary sources that are otherwise hard to find. Using our curated data, we enable our clients to effectively manage their compliance obligations, allowing them to continuously monitor their suppliers and counterparty risks in the MEA region. 

FOOTNOTE
1. https://eiti.org/