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  1. Which instrument governs the Real Beneficiary register, and what did it cancel? → Cabinet Resolution 109 of 2023; Article 22 cancelled Cabinet Resolution 58 of 2020
  2. A person holds exactly 25% of the capital. Are they a real beneficiary? → Yes — Article 5(1) says "25 per cent or more"
  3. A person holds 30% of the voting rights and no shares at all. Do they go on the register? → Yes — ownership and voting are tested independently under Tier 1
  4. Three people jointly hold 30%. What do you record? → Three real beneficiaries at 30% each, never 10% each, under Article 5(4)
  5. How many days do you have to supply additional data the Registrar asks for? → 14 days, not 15
  6. Can a Tier 2 basis be recorded when a Tier 1 person already exists? → Yes — suspicion under Article 5(5) applies regardless
  7. The legal basis for an authority request is the beneficiary's written approval. What must you do? → Attach the written approval, as Article 16(1) requires
  8. Failure to update either register: what is the first-offence fine, and what does the second offence bring? → AED 30,000, then AED 15,000 with a shortened period to correct

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