UBO Transparency in MEASA: What Legal Teams Need to Know

Unlike in the EU or North America, MEASA doesn’t follow a single playbook when it comes to UBO rules. Most countries require some kind of disclosure, but what that looks like and how well it’s enforced varies a lot.

In most countries, the rules fall under anti-money laundering laws. But enforcement is spotty, and even when companies are required to report ownership, the data usually isn’t public. It often sits with regulators or banks, which makes it hard to verify or compare across jurisdictions.

Some MEASA countries are making progress — lowering thresholds, including trusts or rolling out national registers. Others are still catching up. And across the region, there are still plenty of gaps especially when it comes to private companies and foreign ownership.

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Even this small sample shows how inconsistent regulations across the region are — thresholds range from 5% to 25%, public access is rare, and even where registers exist, enforcement is often inconsistent.

Regional Overview: What’s Happening on the Ground

Middle East: Disclosure Required, but Hard to See

Most countries in the Middle East follow FATF guidelines and have Anti-Money Laundering (AML) rules in place. However, public access is almost nonexistent, and enforcement is patchy.

Saudi Arabia and the UAE both require entities to report beneficial owners at the 25% threshold, including trusts. The rules apply across sectors, but there’s no clear way to track foreign-owned entities and oversight can vary depending on the jurisdiction.

‍South Asia: Laws Exist, Enforcement Lags

South Asia has UBO rules on paper, but implementation can be hit-or-miss. In India, People with Significant Control (PSC) reporting applies mostly to listed and regulated companies under the Companies Act and Prevention of Money Laundering Act (PMLA). That leaves a big gap for private entities. 

In Pakistan, only companies regulated by the Securities and Exchange Commission of Pakistan (SECP) are required to disclose beneficial ownership and there’s no central UBO database.

‍Africa: More Progress, but Big Gaps Remain

Africa shows the widest range of UBO regulations, from emerging frameworks to active enforcement.

South Africa is one of the few countries with a public PSC register, launched in 2023. It’s a strong model, but staying up to date remains a challenge. Nigeria takes a stricter approach with a 5% threshold and required PSC filings, though the data isn’t yet publicly accessible.

‍MEASA UBO Compliance Checklist

Disclosure is just the starting point. Here’s what legal and compliance teams should be watching for across the region:

Middle East:

🗸 Are you applying UBO rules consistently, even for non-financial or free zone entities?

🗸 Is your reporting process aligned across onshore, offshore and mainland jurisdictions?

🗸 Are you tracking indirect ownership and trust relationships, even without a public register?

South Asia

🗸 Have you mapped which group entities are actually subject to PSC or UBO rules?

🗸 Are ownership updates built into your workflows, not just reviewed at filing time?

🗸 Is your team staying up to date on changes to the Companies Act and AML enforcement?

Africa

🗸 Are your PSC filings accurate and up to date in countries like South Africa?

🗸 Are you treating low-threshold jurisdictions like Nigeria with extra care?

🗸 Do you have one place to track UBO data across all your African entities?

Cross-Region Essentials

🗸 Are trusts, nominees and indirect ownership all captured in your UBO process?

🗸 Is there a clear owner for UBO compliance on your legal or governance team?

🗸 Are you auditing UBO records across jurisdictions at least once a year?

Transparency is Coming, but Slowly

Across MEASA, UBO rules are shifting, though not always in sync. Public access is rare, enforcement is inconsistent, and even the basics, like thresholds and trust coverage, vary by country.

For legal and compliance teams working across jurisdictions, staying ahead means doing more than just checking the box. It means building internal processes that catch changes early, flag gaps quickly and keep your data clean. To see the full breakdown of UBO rules, reporting triggers and registry access across MEASA, be sure to download the complete 2025 UBO Guide.