Qatar AML/CFT Guide

Qatar has a compact, centrally co-ordinated AML/CFT system. The Qatar Central Bank (QCB) hosts the national committee, supervises most of the financial sector and works closely with QFIU. Firms in the Qatar Financial Centre (QFC) follow their own regulator’s rulebook, but the core thresholds match those onshore.

Qatar’s exposure comes from its role as a regional financial and trading centre, a large migrant workforce that relies on remittances, a large international charitable sector and its location near conflict zones. Its national risk assessment rated both money laundering and terrorist financing risk medium-high.

How the regime fits together

• Policy and co-ordination. The National Anti-Money Laundering and Terrorism Financing Committee (NAMLC) sits at QCB and, since Law No. 18 of 2025, is chaired by the QCB Governor. It leads the national risk assessment and strategy and represents Qatar at MENAFATF and the FATF.
• Financial intelligence. QFIU receives and analyses suspicious transaction reports and passes intelligence to law enforcement and the Public Prosecution.
• Supervision. QCB, the Qatar Financial Markets Authority (QFMA), the QFC Regulatory Authority (QFCRA), the Ministry of Commerce and Industry (MOCI), the Ministry of Justice and the Regulatory Authority for Charitable Activities (RACA) each supervise their sectors.
• Sanctions. The National Counter Terrorism Committee proposes national designations and publishes the sanctions list. The Public Prosecutor makes the designations.
• Enforcement. The Ministry of Interior investigates, and the Public Prosecution prosecutes money laundering and terrorist financing.

Key milestones

1. 2002

   Law No. 28 of 2002 becomes Qatar’s first anti-money laundering law.

2. 2004

   QFIU is set up at QCB, and Qatar becomes one of the 14 founding members of MENAFATF on 30 November.

3. June 2005

   QFIU joins the Egmont Group of financial intelligence units.

4. 2008

   First mutual evaluation by MENAFATF, under the older 40+9 Recommendations.

5. 2010

   Law No. 4 of 2010 replaces the 2002 law. The FATF briefly names Qatar in its early monitoring process from February to October.

6. 2019

   Law No. 20 of 2019 (September) and Law No. 27 of 2019 on Combating Terrorism with the Implementing Regulations (December) set the current framework. The first national risk assessment is adopted.

7. May 2023

   The joint FATF–MENAFATF evaluation is published: 32 compliant and 8 largely compliant ratings.

8. September 2025

   Law No. 18 of 2025 restructures NAMLC and gives QFIU legal personality and operational independence.

What has changed recently

• Law No. 18 of 2025. NAMLC is now chaired by the QCB Governor, with 13 member bodies including, for the first time, the General Tax Authority and RACA. QFIU has its own legal personality and budget.
• QFIU strategy. QFIU launched its 2025–2030 strategic plan on 27 May 2025.
• Inspections of lawyers and brokers. The Ministry of Justice inspected lawyers’ and real estate brokers’ offices for AML/CFT compliance from August to October 2025.
• Electronic reporting for DNFBPs. In June 2026 MOCI and QFIU agreed that businesses supervised by MOCI must register on QFIU’s electronic reporting platform.
• New real estate supervisor. From 1 January 2027 the General Authority for Regulating the Real Estate Sector will supervise real estate brokers, under Council of Ministers Decision No. 38 of 2026.

Qatar’s framework rests on two laws from 2019, one on money laundering and terrorist financing and one on terrorism, with implementing regulations and sector rules underneath. English translations hosted by the QFCRA and MOCI are unofficial; the Arabic texts are authoritative.

Primary laws

Regulations and supervisor rules

Beneficial ownership and charities

• Unified Economic Register. Law No. 1 of 2020 and Council of Ministers Decision No. 12 of 2020 set up the register run by MOCI, which holds basic and beneficial ownership information on companies.
• Charities. Law No. 15 of 2014 regulates charitable activities. RACA licenses charities and must approve their transfers abroad.

Supervision is split by sector, with QCB covering most financial institutions and ministries covering the professions. All suspicious transaction reports go to QFIU.

Supervisors

The financial intelligence unit: QFIU

• Role. Receives and analyses suspicious transaction reports and passes intelligence to law enforcement and the Public Prosecution.
• Status. Set up in 2004 at QCB. Since Law No. 18 of 2025 it has its own legal personality and budget and is operationally independent; the QCB Governor appoints its head.
• International. A member of the Egmont Group since June 2005.
• Reporting. Reports are filed through QFIU’s electronic system. The 2023 FATF evaluation found QFIU well resourced, but its analysis under-used by law enforcement.

Who investigates and prosecutes

The Ministry of Interior investigates money laundering through its economic and cyber crime units. The Public Prosecution prosecutes, and the State Security Bureau takes part in terrorist financing work.

• Customs. The General Authority of Customs receives border declarations, can seize undeclared items and notifies QFIU.
• Anti-corruption. The Administrative Control and Transparency Authority works with NAMLC on corruption-related money laundering.
• Co-ordination. All of these bodies, plus the Ministry of Foreign Affairs and the General Tax Authority, sit on NAMLC.

Targeted financial sanctions

• UN listings. Freeze within 24 hours of a UN designation, without waiting for a national order.
• National listings. Freeze within 12 hours of the designation being announced.
• Reporting. Report frozen assets to your supervisor within 48 hours, with an updated report within 30 days. The supervisor passes reports to the committee and QFIU.
• Scale. The 2023 FATF evaluation recorded QAR 4.26 billion frozen under terrorist financing sanctions.

Qatar’s AML/CFT law covers financial institutions and designated non-financial businesses and professions (DNFBPs) across the state, and firms in the Qatar Financial Centre (QFC) under the QFC Regulatory Authority’s own rulebook. All of them report suspicions to the same financial intelligence unit, QFIU.

Financial institutions

• Supervised by Qatar Central Bank (QCB). Banks, exchange houses, money or value transfer service providers, insurance and reinsurance companies, finance companies and investment companies.
• Supervised by the Qatar Financial Markets Authority (QFMA). Financial brokerage firms, the Qatar Stock Exchange and the Qatar Central Securities Depository.
• Supervised by the QFC Regulatory Authority (QFCRA). Every financial institution authorised in the QFC, under the QFCRA’s Anti-Money Laundering and Combating the Financing of Terrorism Rules 2019.

The law defines a financial institution by activity: anyone who carries on one of the financial activities listed in the Implementing Regulations, as a business, for or on behalf of a customer. Payment service providers licensed by QCB fall in the money transfer group.

Designated non-financial businesses and professions

In the QFC the same categories apply, and the QFCRA rules add auditors, tax consultants and insolvency practitioners. Casinos are not part of the regime because gambling is illegal in Qatar.

Virtual assets

• Not permitted onshore. QCB circulars of 2018 and 2019 say no licence will be issued for virtual asset services, and bar financial institutions from dealing in virtual assets or transferring funds to buy or sell them.
• Tokenisation only in the QFC. The QFC Digital Assets Framework, launched on 1 September 2024, permits tokenised real-world assets. It treats cryptocurrencies, stablecoins and central bank digital currencies as excluded tokens.
• Practical effect. Banks and payment firms should treat flows to and from virtual asset platforms as a risk to assess, not as business they can offer.

Quick check: are you an obliged party?

1. Do you carry on a listed financial activity for customers as a business? If yes, you are a financial institution and QCB, QFMA or the QFCRA supervises you.
2. Are you a real estate agent, a dealer in precious metals or stones, a lawyer, notary, accountant or company service provider? If yes, check whether the activity you carry out is one the law lists.
3. Are you licensed in the QFC? If yes, the QFCRA rules apply in place of the onshore supervisor’s instructions, with the same core thresholds.

Charities are not obliged parties, but the Regulatory Authority for Charitable Activities (RACA) supervises them for terrorist financing risk.

The obligations come from Law No. 20 of 2019 and its Implementing Regulations (Council of Ministers Decision No. 41 of 2019). QCB’s AML/CFT Instructions, the QFCRA and QFMA rules and MOCI’s rules set out the detail for each sector. The core thresholds are the same onshore and in the QFC.

Key numbers

These figures are the ones learners are most often asked about. They were unchanged by the 2025 amendments to the law.

What you must do

Penalties

• Money laundering. Up to 10 years’ imprisonment and a fine of at least QAR 2 million, or twice the amount laundered if higher.
• Terrorist financing. Life imprisonment since 2021, and a fine of QAR 5 million to 10 million, or twice the amount if higher.
• Companies. A fine of QAR 4 million to 8 million, or three times the maximum fine for the offence, with possible suspension or dissolution.
• Tipping off. Up to three years’ imprisonment and a fine of up to QAR 500,000.
• Breaching a freezing order. Up to three years’ imprisonment and a fine of up to QAR 10 million.
• Administrative sanctions (Article 44). Supervisors can fine QAR 25,000 to 100,000 per violation per day, up to QAR 100 million for an institution and QAR 1 million for a director or senior manager, and can restrict or revoke a licence.

Qatar is not a member of the FATF in its own right. It is a founding member of MENAFATF, the FATF-style regional body for the Middle East and North Africa, and is also covered through the Gulf Co-operation Council, which is an FATF member. Its latest evaluation was a joint FATF–MENAFATF assessment published in 2023.

Current status

The 2023 mutual evaluation

• Process. The on-site visit ran from 19 June to 7 July 2022. The FATF plenary adopted the report in February 2023 and it was published on 31 May 2023.
• Technical compliance. No Recommendation was rated partially or non-compliant. The eight largely compliant ratings were R.1 (risk assessment), R.6 and R.7 (terrorist and proliferation financing sanctions), R.8 (non-profit organisations), R.15 (new technologies), R.16 (wire transfers), and R.24 and R.25 (beneficial ownership of legal persons and arrangements). The FATF called Qatar’s technical compliance very strong.
• Substantial effectiveness. Risk understanding and co-ordination (IO.1), supervision (IO.3), confiscation (IO.8) and terrorist financing preventive measures and sanctions (IO.10).
• Moderate effectiveness. International co-operation (IO.2), preventive measures (IO.4), legal persons and arrangements (IO.5), financial intelligence (IO.6), money laundering investigation and prosecution (IO.7) and proliferation financing sanctions (IO.11).
• Low effectiveness. Terrorist financing investigation and prosecution (IO.9). The report found three terrorist financing convictions in 2016–2018 and none since, which it said did not match Qatar’s risk profile.
• Other findings. Money laundering convictions were low against the risk: 20 in person and 9 in absentia over six years. Beneficial ownership information was not kept accurate and up to date. QFIU’s analysis was under-used by law enforcement. Terrorist financing freezes were significant, at QAR 4.26 billion.

How the ratings changed

1. April 2008

   First MENAFATF evaluation, against the older 40+9 Recommendations: 2 compliant, 10 largely compliant, 22 partially compliant and 15 non-compliant, out of 49.

2. February 2010

   The FATF names Qatar in its early monitoring process, the forerunner of the grey list, for gaps in criminalising money laundering and terrorist financing, freezing terrorist assets, due diligence and reporting.

3. October 2010

   The FATF finds Qatar has completed its action plan and ends monitoring.

4. April 2012

   Qatar leaves regular follow-up with MENAFATF.

5. May 2023

   Joint FATF–MENAFATF report: 32 compliant and 8 largely compliant ratings, with no partially or non-compliant ratings. Qatar is placed in enhanced follow-up.

Grey list history

Qatar was briefly named in 2010 in the FATF’s early monitoring process, the forerunner of today’s list of jurisdictions under increased monitoring, and was removed in October 2010. It has not been on the grey list since. It was not on the June 2026 list of 22 jurisdictions.

What comes next

• Follow-up. No follow-up report with re-ratings had been published by 20 October 2026. Because Qatar has no partially or non-compliant ratings, technical re-ratings could only move a Recommendation from largely compliant to compliant.
• Next evaluation. The FATF’s provisional calendar lists a possible on-site visit in June 2029 and a plenary in February 2030. Qatari officials have referred to preparations for an evaluation in 2028, so the timing may change.
• Plenaries to watch. FATF, 26–30 October 2026, Paris; MENAFATF, November 2026, Abu Dhabi.

Qatar’s first national risk assessment, adopted in December 2019, rated the overall money laundering risk medium-high, terrorist financing risk medium-high and proliferation financing risk medium. An update covering 2020 to 2024 is under way but had not been published by October 2026, so the ratings below come from the 2019 assessment as reported in the 2023 FATF evaluation.

Money laundering threats

Qatar is not a major source of criminal proceeds, but the assessment found that its banks can act as a channel for proceeds of crimes committed abroad, and that its growth as a regional financial centre raises that risk. In January 2024 a Qatari court convicted a former finance minister of laundering more than USD 5.6 billion, a reminder that corruption proceeds are part of the picture.

Most vulnerable sectors

The assessment did not give banks a single rating word; it named them among the highest-risk sectors together with exchange houses, dealers in precious metals and stones and trust and company service providers.

Terrorist and proliferation financing

• Channels rated medium-high. Abuse of charities and non-profit organisations, exchange houses, cross-border transfers, bank transfers, cash and bearer instruments, and precious metals and stones.
• Threat actors. Groups operating outside Qatar. The assessment notes attempts by al-Qaida and its affiliates, the Taliban and ISIL to raise funds in Qatar.
• Charities. Qatar has a large international charitable sector. The FATF’s priority is to detect abuse of licensed charities and individual donations diverted to non-charitable purposes.
• Proliferation financing. Rated medium, mainly because of trade and transport links with Iran. No funds had been frozen under proliferation sanctions at the time of the evaluation.

Common typologies

Illustrative patterns linked to the threats and channels the assessment identified.

• Cash and gold. Moving cash or gold across borders without declaring it, or buying gold and jewellery with cash to change its form.
• Foreign proceeds through local banks. Funds from fraud or corruption abroad passing through Qatari accounts or trade payments.
• Exchange houses and transfers. Remittances or cross-border transfers that do not match the sender’s profile or stated purpose.
• Charitable fundraising. Donations collected outside licensed channels, or diverted from stated charitable purposes.

Red flags to watch for

These examples draw on the risks above. They are not an official list; QFIU and the supervisors publish sector guidance.

Eight scenario questions on the main points in this guide. Choose an answer, then open it to check. The answers use only the facts set out above.

1. Question 1. A walk-in customer at a Doha exchange house, with no business relationship, makes two currency exchanges on the same day worth QAR 30,000 and QAR 25,000. What applies?

   1. Nothing, because each transaction is below the threshold
   2. Only the second transaction needs a report to QCB
   3. The transactions are linked and together exceed QAR 50,000, so customer due diligence applies and the split should be reviewed as a possible red flag
   4. The exchange house must refuse the second transaction
   Show answer

   Answer: C. Due diligence applies to occasional transactions of QAR 50,000 or more, including linked smaller ones. Splitting a transaction to stay under a threshold is a red flag to consider for a suspicious transaction report.

2. Question 2. A bank onboards a company owned by three shareholders with 40%, 35% and 25% each. Under Qatar’s rules, which of them are beneficial owners by ownership?

   1. All three, because each holds at least 20%
   2. Only the 40% shareholder
   3. The 40% and 35% shareholders only
   4. None, because no one holds more than 50%
   Show answer

   Answer: A. The beneficial ownership threshold in Qatar is 20% of shares or voting rights, set by Article 15 of the Implementing Regulations and repeated in the QCB, QFCRA and QFMA rules.

3. Question 3. A compliance officer forms a suspicion on a Sunday about a transfer that is not linked to terrorism. By when should the report reach QFIU under its April 2024 instructions?

   1. By the end of the same day
   2. Within three working days
   3. Within 30 days
   4. At the next annual review
   Show answer

   Answer: B. QFIU’s instructions set three working days from forming a suspicion, or 24 hours where terrorism is linked. The law itself says reports must be made promptly.

4. Question 4. A jeweller in Doha is offered QAR 60,000 in cash for a gold necklace. What is the correct response?

   1. Accept the cash and keep a receipt
   2. Accept the cash if the customer shows an ID card
   3. Ask the customer to pay half now and half next week in cash
   4. Decline the cash payment, because cash above QAR 50,000 is banned for jewellery, and consider whether the attempt is suspicious
   Show answer

   Answer: D. Law No. 4 of 2022 bans cash payments above QAR 50,000 for precious metals, stones and jewellery. Splitting the payment to avoid the limit is also a breach and a red flag.

5. Question 5. The UN Security Council lists a person who holds an account at a Qatari bank. What must the bank do?

   1. Wait for a court order before acting
   2. Close the account and pay out the balance
   3. Freeze the funds within 30 days
   4. Freeze the funds within 24 hours of the UN designation and report to its supervisor within 48 hours
   Show answer

   Answer: D. UN listings must be frozen within 24 hours without waiting for a national order, and frozen assets reported to the supervisor within 48 hours.

6. Question 6. A fintech start-up wants to open a crypto exchange for retail customers in Doha. What is the position?

   1. It can apply to QCB for a virtual asset licence
   2. It can operate freely if it stays below QAR 50,000 per trade
   3. Virtual asset services are not permitted onshore, and the QFC framework excludes cryptocurrencies
   4. It only needs to register with QFIU
   Show answer

   Answer: C. QCB circulars bar virtual asset services and say no licence will be issued. The QFC Digital Assets Framework permits tokenised real-world assets but treats cryptocurrencies and stablecoins as excluded tokens.

7. Question 7. A real estate broker asks who will supervise brokers for AML/CFT in 2027. What is the answer?

   1. The General Authority for Regulating the Real Estate Sector, from 1 January 2027
   2. The Ministry of Justice, with no change
   3. Qatar Central Bank
   4. QFIU
   Show answer

   Answer: A. Council of Ministers Decision No. 38 of 2026 moves supervision of real estate brokers from the Ministry of Justice to the real estate authority from 1 January 2027.

8. Question 8. A colleague says Qatar is on the FATF grey list because it is in enhanced follow-up. Is that right?

   1. Yes, enhanced follow-up and the grey list are the same
   2. No, Qatar is not on the grey list; enhanced follow-up is a separate reporting process after its 2023 evaluation
   3. Yes, Qatar has been on the grey list since 2023
   4. No, because Qatar has never been evaluated
   Show answer

   Answer: B. Qatar was not on the June 2026 grey list. Enhanced follow-up means it reports back to MENAFATF more often; it was briefly monitored by the FATF only in 2010.