Holding Restrictions – Investment Funds – United Arab Emirates
Restrictions on clients
No general restrictions on client residency for holdings held through CBL. However, certain funds may impose specific restrictions on investor domicile.
Some restrictions include:
- Anti-money laundering and sanctions legislation mandates all investors to be onboarded into the Investment Fund, with certain investors may be deemed higher risk due to their country of domicile.
- UAE funds are also subject to AML laws which impose restrictions on transactions with residents from “high risk” / blacklisted jurisdictions.
- The Investment Funds Regulation allows Investment Funds to set nationality restrictions for unitholders through their offering documents, but such restrictions apply only to the specific Investment Fund implementing them
Restrictions on settlement
There is no general restriction on settlement, however certain funds may impose specific settlement or transfer restrictions. Clients must refer to and abide by the restrictions (if any) contained in the fund prospectus before entering into transactions.
UAE:
- Clients must refer to and abide by the restrictions (if any) contained in the fund prospectus before entering into transactions.
ADGM:
- No specific settlement restrictions under ADGM law.
- If a fund applies specific restrictions, investors must comply based on fund documentation.
DIFC:
- No general settlement restrictions exist under DIFC law.
Fund-specific settlement restrictions may apply, which are outlined in the fund prospectus.
Disclaimer
The information contained in the Holding Restrictions is based on the legal opinion obtained by CBL that was issued on the 11th April 2025, CBL believes the information to be correct but disclaims any responsibility as to the accuracy and completeness of the information. In the case of discrepancy between the information provided by CBL and the local laws and regulations, the latter shall prevail. The Holding Restrictions do not constitute legal advice and clients should seek advice from independent professional counsel.
Clients are responsible for ensuring compliance with the holding restrictions and agree to indemnify and hold harmless CBL, for any loss, expense, liability, damage, or claims, whether direct or indirect, against or incurred by CBL arising out of or resulting from such non-compliance.