Middle East & North Africa · Country guide
Saudi Arabia AML/CFT Guide
How Saudi Arabia’s AML/CFT regime works: who supervises, where suspicious transaction reports go, the key laws, and what the latest FATF assessment found.
Contents Overview
Section 01
Overview
- The core laws are the AML Law and the Counter-Terrorism Law, both from 2017 and both amended in 2026.
- Report suspicious transactions immediately and directly to the General Directorate of Financial Intelligence (SAFIU), whatever the amount.
- Keep records for at least ten years, twice the FATF minimum.
- Freeze the funds of listed persons within hours and without prior notice, and notify your supervisor within five working days.
- Saudi Arabia is not under FATF increased monitoring. Its next mutual evaluation is due, with an on-site visit planned for November 2026.
- There is no licensing regime for virtual asset service providers, and virtual currencies are not legal tender.
Saudi Arabia’s AML/CFT regime rests on two laws issued in 2017: the Anti-Money Laundering Law (Royal Decree No. M/20 of 1439H), amended in April 2026, and the Law on Combating Crimes of Terrorism and its Financing (Royal Decree No. M/21 of 1439H), amended in June 2026. Each has implementing regulations, and the AML regulations were updated in June 2026. Saudi Arabia has been a full member of the FATF since 2019 and is a founding member of MENAFATF.
How the regime is organised
- Policy and coordination. The Permanent Committee for Combating Money Laundering, chaired by the Governor of the Saudi Central Bank (SAMA) and made up of 18 government bodies, coordinates AML policy. The April 2026 amendment put it on a statutory footing and gave it the job of setting risk-based national policy. The Permanent Committee for Combating Terrorism and its Financing, housed at the Presidency of State Security, coordinates counter-terrorist financing policy and handles UN sanctions requests.
- Financial intelligence. The General Directorate of Financial Intelligence, also known as the Saudi Arabia Financial Investigation Unit (SAFIU), receives and analyses suspicious transaction reports. It operates independently under the oversight of the President of State Security and is a member of the Egmont Group of FIUs.
- Supervision. SAMA supervises banks, finance companies, money exchangers and payment providers; the Insurance Authority supervises insurers (since November 2023); the Capital Market Authority (CMA) supervises securities firms; the Ministry of Commerce supervises dealers in precious metals and stones and accountants; the Real Estate General Authority (REGA) supervises real estate brokers; the Ministry of Justice supervises lawyers; and the National Center for the Development of the Non-Profit Sector oversees non-profit organisations.
- Borders. The Zakat, Tax and Customs Authority (ZATCA) runs the cross-border declaration system. Since June 2026, travellers must declare cash, bearer instruments, gold and other precious items worth SAR 40,000 or more, down from SAR 60,000.
- Investigation and prosecution. The Public Prosecution investigates and prosecutes money laundering, the Presidency of State Security leads on terrorism and terrorist financing, and the Oversight and Anti-Corruption Authority (Nazaha) tackles corruption.
Key milestones
- 1999
The Permanent Committee for Combating Money Laundering is created.
- 2004
Saudi Arabia is one of the 14 founding members of MENAFATF.
- 2015
Saudi Arabia becomes an FATF observer.
- 2017
The first national ML and TF risk assessments are completed. New AML and Counter-Terrorism Laws are issued in October and November, and FATF and MENAFATF assessors carry out the on-site visit for the mutual evaluation in November.
- 2018
The mutual evaluation is adopted in June and published in September.
- June 2019
Saudi Arabia becomes a full member of the FATF. Its first follow-up report is adopted in October.
- 2020
The Anti-Commercial Concealment Law targets businesses run by non-Saudis behind a Saudi front.
- 2023
The Insurance Authority takes over insurance supervision from SAMA.
- 2025
The Ministry of Commerce’s beneficial ownership rules take effect in April, and public summaries of new national ML and proliferation financing risk assessments are released. The CMA issues rules on targeted financial sanctions in December.
- 2026
The AML Law is amended in April. In June, the Counter-Terrorism Law is amended, a new law on managing seized and confiscated funds is approved, and updated AML regulations lower the border declaration threshold. FATF assessors are due on site in November.
What has changed most for firms
- Statutory national policy. The Permanent Committee now sets risk-based national AML policy and assesses high-risk countries under the AML Law.
- Tougher consequences for individuals. Saudi nationals convicted of money laundering face a travel ban as long as their prison term, and foreign nationals are deported and may return only for Hajj or Umrah. Courts can also confiscate assets that are out of proportion to a person’s lawful income unless a lawful source is proven.
- Beneficial ownership transparency. Since April 2025, companies must keep a beneficial ownership register in the Kingdom, identify anyone with 25% or more, report changes within 15 days and confirm the register every year, with fines of up to SAR 500,000.
- Lower border threshold. Declarations are now required from SAR 40,000, with fines of 10% to 25% of the value for a first breach.
- Commercial concealment. The crackdown on tasattur continues. In November 2025 alone, the Ministry of Commerce carried out 4,242 inspections and found 98 suspected cases.
Sources for this section (21)
- Anti-Money Laundering Law, consolidated English text (AML Permanent Committee) (opens in a new tab)
- Umm Al-Qura: AML Law amendment, April 2026 (opens in a new tab)
- CMS on the 2026 AML Law changes (opens in a new tab)
- Umm Al-Qura: updated AML Implementing Regulations, June 2026 (opens in a new tab)
- Umm Al-Qura: Counter-Terrorism Law amendments, June 2026 (opens in a new tab)
- Umm Al-Qura: Law on Management of Seized and Confiscated Funds, 2026 (opens in a new tab)
- Law on Combating Crimes of Terrorism and its Financing (SAMA Rulebook) (opens in a new tab)
- AML Permanent Committee: about (opens in a new tab)
- Saudi Arabia’s submission to the UN on counter-terrorism measures (opens in a new tab)
- US International Trade Administration on the Insurance Authority, 2023 (opens in a new tab)
- REGA guidance for real estate brokers (Arabic) (opens in a new tab)
- Zawya on the new border declaration threshold, June 2026 (opens in a new tab)
- AML Permanent Committee on FATF membership, June 2019 (opens in a new tab)
- FATF plenary outcomes, June 2019 (opens in a new tab)
- FATF: Saudi Arabia mutual evaluation, 2018 (opens in a new tab)
- FATF assessment calendar (opens in a new tab)
- Ministry of Commerce on the Anti-Commercial Concealment Law, 2020 (opens in a new tab)
- Ministry of Commerce on concealment inspections, December 2025 (opens in a new tab)
- Addleshaw Goddard on the beneficial ownership rules, 2025 (opens in a new tab)
- National ML Risk Assessment 2025, public summary (opens in a new tab)
- CMA Implementing Rules on Targeted Financial Sanctions, 2025 (opens in a new tab)
Section 02
Legal and regulatory framework
The framework has three layers: laws issued by Royal Decree, implementing regulations, and rules and guidance from each supervisor.
Primary laws and regulations
Anti-Money Laundering Law (Royal Decree No. M/20 of 1439H)
The core AML law, issued in October 2017 and amended by Royal Decree No. M/223 in April 2026.
- The money laundering offence (Article 2) and duties on customer due diligence, PEPs, wire transfers and record keeping (Articles 5 to 13)
- Suspicious transaction reports to the FIU (Article 15), tipping off and good-faith protection (Article 16), and the FIU itself (Article 17)
- Administrative sanctions by supervisors (Article 25): warnings, fines of up to SAR 5 million per violation, bans, removal of managers and licence suspension or revocation
- Criminal penalties (Articles 26 to 31): two to ten years’ imprisonment and/or a fine of up to SAR 5 million; three to 15 years and/or up to SAR 7 million in aggravated cases; and for legal persons, up to SAR 50 million and at least double the value of the funds
AML Implementing Regulations
Updated and published in June 2026. Under the 2026 amendment, they are issued by the President of State Security in agreement with the Minister of Finance, the Public Prosecutor and the SAMA Governor.
- Covered financial activities, DNFBPs and their supervisors (Article 1)
- Customer due diligence, beneficial ownership at 25% and politically exposed persons (Articles 7 and 8)
- Wire transfer information (Article 10)
- Declaration of SAR 40,000 or more in cash, bearer instruments, gold, precious metals, gems and jewellery at the border (Article 23)
Law on Combating Crimes of Terrorism and its Financing (Royal Decree No. M/21 of 1439H)
Issued in November 2017, replacing the 2014 law. Its implementing regulations followed in 2019, and both were amended in June 2026.
- The terrorist financing offence (Article 47): five to 15 years’ imprisonment, and at least ten years for abuse of a professional position
- The Permanent Committee for Combating Terrorism and its Financing, and requests under UN Security Council resolutions (Articles 75 and 84)
- Supervisory sanctions of up to SAR 5 million per violation (Article 83)
Targeted financial sanctions mechanisms
UN terrorism sanctions are implemented through the Permanent Committee and the supervisors. A separate mechanism, approved by High Order No. 10130 of 1439H, covers proliferation financing.
- Freeze within hours of a listing, without prior notice to the person
- Notify the supervisor of a freeze within five working days, under SAMA’s guide
Anti-Commercial Concealment Law (2020)
Targets tasattur, where a non-Saudi runs a business for their own account behind a Saudi national’s name.
- Up to five years’ imprisonment and fines of up to SAR 5 million, with confiscation of illicit funds
- Closure, licence cancellation, collection of zakat and tax due, public naming and deportation of non-Saudis
Ultimate Beneficial Ownership Rules (Ministry of Commerce, 2025)
In force since 3 April 2025 for companies registered under the Companies Law.
- A beneficial owner holds 25% or more of ownership or voting rights, can appoint or remove most of the board, or has other control. If no one qualifies, a manager or board member is named
- Keep the register in the Kingdom, report changes within 15 days and confirm it every year. Fines reach SAR 500,000
Sector rules
Saudi Central Bank (SAMA)
AML/CTF rules and guides in the SAMA Rulebook, including its guide to implementing UN Security Council resolutions
Banks, finance companies, money exchangers and payment service providers
Insurance Authority
AML/CTF requirements for the insurance sector, which moved from SAMA in November 2023
Insurers and insurance service providers
Capital Market Authority (CMA)
AML/CTF rules and the Implementing Rules on Targeted Financial Sanctions (December 2025)
Capital market institutions
Ministry of Commerce
AML/CFT requirements and guidance for DNFBPs, including tighter customer checks for gold and gem dealers from 2025
Dealers in precious metals and stones, and accountants
Real Estate General Authority (REGA)
AML/CFT guidance for licensed brokers under the Real Estate Brokerage Law
Real estate brokers
Ministry of Justice
AML/CFT requirements for the legal profession
Lawyers
Key guidance
- The 2025 public summaries of the national money laundering risk assessment (overall medium) and proliferation financing risk assessment (medium-low), published by the AML Permanent Committee
- SAMA’s guide to implementing UN Security Council resolutions on terrorism and its financing, and its mechanism for proliferation financing
- The CMA’s Implementing Rules on Targeted Financial Sanctions (December 2025)
- REGA’s guidance on AML/CFT obligations for real estate brokers
Sources for this section (19)
- Anti-Money Laundering Law, consolidated English text (AML Permanent Committee) (opens in a new tab)
- Anti-Money Laundering Law, English translation (MISA) (opens in a new tab)
- Umm Al-Qura: AML Law amendment, April 2026 (opens in a new tab)
- CMS on the 2026 AML Law changes (opens in a new tab)
- Umm Al-Qura: updated AML Implementing Regulations, June 2026 (opens in a new tab)
- AML Law penalties (SAMA Rulebook) (opens in a new tab)
- Law on Combating Crimes of Terrorism and its Financing (SAMA Rulebook) (opens in a new tab)
- Umm Al-Qura: Counter-Terrorism Law amendments, June 2026 (opens in a new tab)
- Saudi Arabia’s submission to the UN on counter-terrorism measures (opens in a new tab)
- SAMA guide to implementing UN Security Council resolutions (opens in a new tab)
- SAMA: proliferation financing mechanism (opens in a new tab)
- CMA Implementing Rules on Targeted Financial Sanctions, 2025 (opens in a new tab)
- Ministry of Commerce on the Anti-Commercial Concealment Law, 2020 (opens in a new tab)
- Addleshaw Goddard on the beneficial ownership rules, 2025 (opens in a new tab)
- Greenberg Traurig on the beneficial ownership rules, 2025 (opens in a new tab)
- Asharq Al-Awsat on new rules for gold and gem dealers, 2025 (opens in a new tab)
- REGA guidance for real estate brokers (Arabic) (opens in a new tab)
- National ML Risk Assessment 2025, public summary (opens in a new tab)
- National PF Risk Assessment 2025, public summary (opens in a new tab)
Section 03
Supervisors and the FIU
Responsibility is split between two national committees, the sector supervisors, the FIU and the agencies that investigate and prosecute. Many key functions sit with the Saudi Central Bank or the Presidency of State Security.
Supervisors by sector
Saudi Central Bank (SAMA)
Banks, finance companies, money exchangers and payment service providers. Its Governor also chairs the Permanent Committee for Combating Money Laundering
Insurance Authority
Insurers and insurance service providers. It took over insurance supervision from SAMA in November 2023
Capital Market Authority (CMA)
Capital market institutions, such as brokers, asset managers and custodians
Ministry of Commerce
Dealers in precious metals and stones, and accountants. It also enforces the Anti-Commercial Concealment Law and the beneficial ownership rules
Real Estate General Authority (REGA)
Licensed real estate brokers, under the Real Estate Brokerage Law
Ministry of Justice
Lawyers. Notaries are civil servants, so they are not supervised as a business sector
National Center for the Development of the Non-Profit Sector
Non-profit organisations. The General Authority of Awqaf oversees endowments (waqfs)
Zakat, Tax and Customs Authority (ZATCA)
Cross-border declarations of cash, bearer instruments, gold and other precious items worth SAR 40,000 or more, at all land, sea and air ports
The financial intelligence unit (SAFIU)
- Status. The General Directorate of Financial Intelligence, also known as the Saudi Arabia Financial Investigation Unit (SAFIU), is set up in Riyadh under Article 17 of the AML Law. It works under the oversight of the President of State Security, with operational independence.
- Reports it receives. Suspicious transaction reports from financial institutions and DNFBPs, filed immediately and directly, whatever the amount. Reports on suspected terrorist financing also go to it under the Counter-Terrorism Law.
- How reports are filed. Electronically, through SAFIU’s reporting system. SAMA moved banks to electronic filing in 2019.
- What it does with them. Analyses reports, passes the results to the competent authorities, and can ask reporting entities for further information.
- International cooperation. SAFIU is a member of the Egmont Group. It exchanges information with other Egmont FIUs and has signed 49 memoranda of understanding with foreign counterparts.
- Guidance. The AML Permanent Committee publishes the national risk assessments and guidance for reporting entities on its website.
Who investigates and prosecutes
- The Public Prosecution investigates and prosecutes money laundering. It can ask the courts to confiscate assets that are out of proportion to lawful income, and can extend border seizures to 60 days
- The Presidency of State Security leads on terrorism and terrorist financing, and houses the Permanent Committee for Combating Terrorism and its Financing
- The Oversight and Anti-Corruption Authority (Nazaha) investigates corruption, one of the main sources of criminal proceeds
- Under the 2026 law on seized and confiscated funds, a permanent committee chaired by the General Authority for Guardianship of Minors’ Funds oversees how seized and confiscated assets are managed
Past cases show the scale. In 2022, authorities seized SAR 4 billion in a case in which six people received sentences of up to 25 years, and in 2023 seven people were convicted of laundering SAR 1.035 billion through company accounts.
Targeted financial sanctions
Permanent Committee for Combating Terrorism and its Financing
Receives requests under UN Security Council resolutions from other states and organisations, and coordinates how they are implemented
Presidency of State Security
Publishes the national list of designated persons and issues freezing requests, which reach firms through their supervisors
Supervisors
Pass freezing requests on to firms, check that they screen and freeze, and receive notification of freezes
Proliferation financing
A separate mechanism, High Order No. 10130 of 1439H, covers UN sanctions on weapons of mass destruction. Freezes are immediate and must be reported within a week
- Freeze within hours. SAMA’s guide requires firms to freeze promptly, within hours and without prior notice. The CMA’s 2025 rules add that a freeze cannot wait for internal committee approval.
- Screen continuously. SAMA expects customer databases to be checked daily against updated lists. The CMA requires screening at onboarding, before transactions, whenever lists change and in full at least every quarter, with a 12-month lookback for newly listed persons.
- Report. Notify the supervisor of a freeze within five working days, and file an STR with SAFIU where there are signs of sanctions evasion.
- Delisting. When the UN removes a listing, unfreeze within hours and notify SAMA within five working days.
Sources for this section (20)
- Anti-Money Laundering Law, consolidated English text (AML Permanent Committee) (opens in a new tab)
- AML Law, Article 17: the FIU (SAMA Rulebook) (opens in a new tab)
- AML Permanent Committee: about (opens in a new tab)
- AML Permanent Committee: guidance and reports (opens in a new tab)
- Saudi Arabia’s submission to the UN on counter-terrorism measures (opens in a new tab)
- SAMA circular on electronic STR filing, 2019 (via RegAlert) (opens in a new tab)
- US International Trade Administration on the Insurance Authority, 2023 (opens in a new tab)
- REGA guidance for real estate brokers (Arabic) (opens in a new tab)
- Ministry of Commerce on concealment inspections, December 2025 (opens in a new tab)
- Umm Al-Qura: updated AML Implementing Regulations, June 2026 (opens in a new tab)
- Zawya on the new border declaration threshold, June 2026 (opens in a new tab)
- CMS on the 2026 AML Law changes (opens in a new tab)
- Umm Al-Qura: Law on Management of Seized and Confiscated Funds, 2026 (opens in a new tab)
- Law on Combating Crimes of Terrorism and its Financing (SAMA Rulebook) (opens in a new tab)
- SAMA guide to implementing UN Security Council resolutions (opens in a new tab)
- SAMA: proliferation financing mechanism (opens in a new tab)
- CMA Implementing Rules on Targeted Financial Sanctions, 2025 (opens in a new tab)
- FATF and MENAFATF mutual evaluation report, 2018 (PDF) (opens in a new tab)
- Argaam on the SAR 4 billion case, September 2022 (opens in a new tab)
- Saudi Gazette on the SAR 1.035 billion case, October 2023 (opens in a new tab)
Section 04
Who must comply
AML/CFT obligations apply to financial institutions and designated non-financial businesses and professions (DNFBPs). The AML Law defines financial institutions by the activities they carry out, and the implementing regulations list the DNFBPs and the conditions under which they are covered.
Financial institutions
Article 1 of the implementing regulations lists the activities that make a business a financial institution. They include:
- Taking deposits, including private banking
- Lending, leasing and other financing
- Money or value transfer
- Issuing and managing means of payment, including e-wallets
- Financial guarantees
- Trading in securities and foreign exchange, and other securities activities
- Portfolio management, custody and asset management
- Insurance and investment-linked products
In practice this covers banks, finance companies, money exchangers and payment service providers (supervised by SAMA), insurers (Insurance Authority) and capital market institutions (CMA).
DNFBPs and when they are covered
Real estate brokers
When they act for clients in buying or selling property
Supervisor: Real Estate General Authority (REGA)
Dealers in gold, precious metals and stones
When they carry out a cash transaction with a customer of SAR 50,000 or more
Supervisor: Ministry of Commerce
Lawyers
When they prepare or carry out transactions for clients involving buying or selling real estate, managing client money or assets, setting up, operating or managing companies and other legal persons or arrangements, or buying and selling businesses
Supervisor: Ministry of Justice
Accountants
When they carry out the same activities for clients
Supervisor: Ministry of Commerce
Company formation and trust services are covered when lawyers or accountants provide them. Notaries are civil servants rather than a business sector, and casinos are prohibited. Since 2025 the Ministry of Commerce has also tightened customer due diligence rules for gold and gem dealers.
Virtual assets
- No licensing regime. Saudi Arabia has no licensing regime for virtual asset service providers, and virtual currencies are not legal tender. SAMA has warned the public against them, and banks and payment providers do not support crypto trading or payments.
- Regulated by substance. Tokens that work like securities fall under the CMA, and payment-type activity under SAMA’s payments rules. A first regulated real estate tokenisation project runs under joint REGA and CMA supervision.
- What it means for firms. Treat customers with crypto exposure as higher risk, ask where their funds come from, and watch for transfers to and from overseas exchanges. The AML Permanent Committee publishes red flag indicators for virtual assets.
Non-profit organisations
Non-profit organisations are overseen by the National Center for the Development of the Non-Profit Sector and, for endowments, the General Authority of Awqaf, mainly to protect them from misuse for terrorist financing. The April 2026 amendment removed references to non-profit organisations from several AML Law duties, including suspicious transaction reporting.
Quick check: is your business covered?
- Do you carry out any of the financial activities listed above? If so, you are a financial institution, supervised by SAMA, the Insurance Authority or the CMA.
- Are you a real estate broker, a dealer in gold or precious stones, a lawyer or an accountant, and do you carry out a covered activity, such as a cash sale of SAR 50,000 or more or a property deal for a client? If so, DNFBP obligations apply.
- Do you deal in virtual assets? No licence is available, so take legal advice before offering any service.
If you are covered, register with your supervisor and make sure you can file reports with SAFIU before you need to.
Sources for this section (13)
- Umm Al-Qura: updated AML Implementing Regulations, June 2026 (opens in a new tab)
- Anti-Money Laundering Law, consolidated English text (AML Permanent Committee) (opens in a new tab)
- SAMA Rules on Combating Money Laundering and Terrorist Financing (SAMA Rulebook) (opens in a new tab)
- US International Trade Administration on the Insurance Authority, 2023 (opens in a new tab)
- REGA guidance for real estate brokers (Arabic) (opens in a new tab)
- Asharq Al-Awsat on new rules for gold and gem dealers, 2025 (opens in a new tab)
- FATF and MENAFATF mutual evaluation report, 2018 (PDF) (opens in a new tab)
- Z&Co on crypto platforms and fiat rails in Saudi Arabia, February 2026 (Mondaq) (opens in a new tab)
- Legal 500: Saudi Arabia fintech guide (opens in a new tab)
- FintechAsia on Saudi crypto regulation, October 2026 (opens in a new tab)
- AML Permanent Committee: guidance and reports (opens in a new tab)
- CMS on the 2026 AML Law changes (opens in a new tab)
- AML Permanent Committee: about (opens in a new tab)
Section 05
Key obligations
These are the core obligations for financial institutions and DNFBPs under the AML Law and its implementing regulations, together with the sanctions rules. SAMA, the CMA and the other supervisors add sector-specific rules, so always read them alongside your supervisor’s requirements.
Key numbers and qualifications
Read these summaries with the detailed duties below and the rules for your sector. The linked provisions explain their scope.
What you must do
01Customer due diligence
AML Law, Articles 6 and 7; implementing regulations, Article 7
- Carry out CDD before opening an account or e-wallet, starting a business relationship or carrying out an occasional transaction
- Identify and verify the customer and the beneficial owner using reliable, independent sources. Verification can be completed after the relationship starts only where the risk is lower, and then as soon as possible
- Take a risk-based approach, with enhanced measures where the risk is high
- Never open anonymous, numbered or fictitious accounts
02PEPs and high-risk countries
AML Law, Articles 8 and 11; implementing regulations, Article 8
- Politically exposed persons include foreign and domestic holders of prominent public functions, such as heads of state or government, senior politicians, officials, judges and military officers, senior executives of state-owned companies and important party officials, as well as senior people at international organisations
- Family members (relatives by blood or marriage up to the second degree) and close associates are covered too
- For foreign PEPs, get senior management approval, establish the source of wealth and funds, and monitor the relationship more closely. Apply the same measures to domestic and international organisation PEPs where the risk is higher
- Apply enhanced due diligence to relationships and transactions with high-risk countries
03Beneficial ownership
Implementing regulations, Article 7; Ministry of Commerce rules (2025)
- Identify the natural persons who own or control 25% or more. If there are none, identify whoever controls the customer by other means, and failing that, the senior managing official
- Companies must keep their own beneficial ownership register in the Kingdom, report changes within 15 days and confirm it every year. Use it as one source, but verify ownership yourself
04Reporting to SAFIU
AML Law, Articles 15 to 17 and 25
- Report suspicious transactions immediately and directly to SAFIU, whatever the amount
- Never tell the customer or anyone else that a report has been or will be made. Disclosures to lawyers and competent authorities are allowed
- Reports made in good faith are protected from liability
- Breaches can lead to administrative sanctions, including fines of up to SAR 5 million per violation and action against managers
05Record keeping
AML Law, Articles 12 and 13
- Keep transaction records for at least ten years from the transaction or the closure of the account
- Keep customer due diligence records for at least ten years after the relationship ends or the occasional transaction is completed
- Keep records of your reviews of complex or unusual transactions for ten years. The Public Prosecution can require them to be kept for longer
06Targeted financial sanctions
Counter-Terrorism Law; SAMA and CMA sanctions rules
- Screen customers and transactions against UN and national lists at onboarding, before transactions and whenever the lists change
- Freeze within hours, without prior notice and without waiting for internal approval, and do not make funds or services available to listed persons
- Notify your supervisor of a freeze within five working days, and file an STR with SAFIU where there are signs of sanctions evasion
07Wire transfers
AML Law, Article 10; implementing regulations, Article 10
- Obtain originator and beneficiary information for domestic and cross-border transfers in any currency. There is no minimum amount
- Do not carry out a transfer if the required information is missing
- SAMA’s rules also require the purpose of the transfer to be recorded, and wire transfer records must be kept for ten years
08Risk assessment and compliance programme
AML Law, Articles 5 and 14; implementing regulations, Articles 5 and 14
- Identify, assess, document and update your money laundering and terrorist financing risks
- Appoint a compliance officer at senior management level, train staff on an ongoing basis and keep an independent audit function
- Run group-wide programmes and share information within the group where the law allows
Sources for this section (11)
- Anti-Money Laundering Law, consolidated English text (AML Permanent Committee) (opens in a new tab)
- Umm Al-Qura: updated AML Implementing Regulations, June 2026 (opens in a new tab)
- AML Law penalties (SAMA Rulebook) (opens in a new tab)
- SAMA Rules on Combating Money Laundering and Terrorist Financing (SAMA Rulebook) (opens in a new tab)
- Addleshaw Goddard on the beneficial ownership rules, 2025 (opens in a new tab)
- Law on Combating Crimes of Terrorism and its Financing (SAMA Rulebook) (opens in a new tab)
- SAMA guide to implementing UN Security Council resolutions (opens in a new tab)
- SAMA: proliferation financing mechanism (opens in a new tab)
- CMA Implementing Rules on Targeted Financial Sanctions, 2025 (opens in a new tab)
- CMS on the 2026 AML Law changes (opens in a new tab)
- Zawya on the new border declaration threshold, June 2026 (opens in a new tab)
Section 06
FATF assessment and status
Saudi Arabia has been a full member of the FATF since June 2019, after four years as an observer, and is a founding member of MENAFATF. Its mutual evaluations are carried out jointly by the FATF and MENAFATF. The last full evaluation was published in 2018, and the next is due to start with an on-site visit in November 2026.
Current status
The 2018 mutual evaluation
- Process. A joint FATF and MENAFATF assessment, with an on-site visit from 8 to 23 November 2017. The report was adopted in June 2018 and published on 24 September 2018.
- Effectiveness. No Immediate Outcome was rated high. Four were rated substantial (risk and coordination, supervision, terrorist financing investigation, and terrorist financing prevention and sanctions), four moderate (international cooperation, preventive measures, legal persons and financial intelligence) and three low (money laundering investigation and prosecution, confiscation, and proliferation financing sanctions).
- Technical compliance. 36 of the 40 Recommendations were rated compliant or largely compliant: 19 compliant and 17 largely compliant. Four were partially compliant (R.6, R.7, R.33 and R.36), and none non-compliant.
- Strengths. Strong coordination between agencies, and a substantial response to terrorist financing, with more than 1,700 terrorist financing investigations and over 1,100 convictions since 2013.
- Main gaps. Money laundering investigations were reactive and unsophisticated, and rarely targeted professional launderers. Little criminal property was confiscated or recovered, although an estimated 70% to 80% of domestic proceeds of crime left the country. Saudi Arabia did not effectively seek international cooperation in money laundering cases, and proliferation financing sanctions were weak.
- Result. Saudi Arabia was placed in enhanced follow-up.
Progress since 2018
- June 2019
The FATF granted Saudi Arabia full membership, based on its commitment to complete the items on its action plan.
- October 2019: first follow-up report
R.6 and R.7 (targeted financial sanctions) were upgraded to largely compliant. R.18 and R.21 were lowered from compliant to largely compliant because the FATF Standards had changed. Saudi Arabia reached 38 of 40: 17 compliant and 21 largely compliant. Only R.33 (statistics) and R.36 (international instruments) remain partially compliant. The report was published in January 2020, and Saudi Arabia stayed in enhanced follow-up.
- November 2024
Riyadh hosted the 39th MENAFATF plenary, marking the body’s 20th anniversary.
- 2025
Public summaries of new national money laundering and proliferation financing risk assessments were released, and the CMA issued rules on targeted financial sanctions.
- 2026
The AML Law, the Counter-Terrorism Law and the AML regulations were updated, and a new law on managing seized and confiscated funds was approved ahead of the next evaluation.
Membership and listing history
Saudi Arabia was one of the 14 founding members of MENAFATF in 2004. It became an FATF observer in June 2015 and a full member in June 2019, the first Arab country to do so, according to its AML Permanent Committee. It has not been placed under FATF increased monitoring. In 2019 the European Commission proposed adding Saudi Arabia to the EU list of high-risk third countries, but EU member states rejected that list, and Saudi Arabia is not on the current EU list.
What comes next
- Saudi Arabia’s next mutual evaluation is a joint FATF and MENAFATF assessment under the new round of evaluations. The FATF’s calendar lists a possible on-site visit in November 2026 and plenary discussion in June 2027, and notes that dates may change.
- Effectiveness has not been reassessed since 2018. The weakest areas then, money laundering prosecutions, confiscation and proliferation financing sanctions, are likely to be closely examined.
- Several recent reforms relate directly to those areas, including confiscation of unexplained wealth, the new law on managing seized assets and the CMA’s sanctions rules.
Sources for this section (14)
- FATF country profile: Saudi Arabia (opens in a new tab)
- FATF: Saudi Arabia mutual evaluation, 2018 (opens in a new tab)
- Mutual evaluation report, 2018 (PDF) (opens in a new tab)
- Mutual evaluation, executive summary (PDF) (opens in a new tab)
- FATF: Saudi Arabia follow-up report, 2020 (opens in a new tab)
- Follow-up report, 2020 (PDF) (opens in a new tab)
- FATF plenary outcomes, June 2019 (opens in a new tab)
- AML Permanent Committee on FATF membership, June 2019 (opens in a new tab)
- MENAFATF: about (opens in a new tab)
- AML Permanent Committee: mutual evaluation (opens in a new tab)
- AML Permanent Committee on the 39th MENAFATF plenary, November 2024 (opens in a new tab)
- FATF assessment calendar (opens in a new tab)
- eucrim on the EU Council rejecting the 2019 list (opens in a new tab)
- Bird & Bird on the EU high-risk country list, 2026 (opens in a new tab)
Section 07
Risks and red flags
Saudi Arabia completed its first national money laundering and terrorist financing risk assessments in 2017. In 2025 the AML Permanent Committee published public summaries of updated assessments, which rate the overall money laundering risk as medium and proliferation financing risk as medium-low. Your own risk assessment should reflect these findings.
Money laundering threats
Criminal proceeds are mostly held in cash, and the offences are mainly committed by organised groups. The public summary does not rank the other predicate offences.
The 2017 assessment put criminal proceeds at an estimated USD 12 billion to 32 billion, with 70% to 80% of domestic proceeds flowing out of the country. By source, drug trafficking accounted for 31% of proceeds, corruption 22%, counterfeiting and piracy 21% and customs smuggling 8%.
Sector exposure
The 2025 summary names banks and gold dealers as the most exposed sectors. In 2017, money remitters were also among the highest-risk sectors.
Terrorist and proliferation financing
- Terrorist financing threat. The 2018 evaluation describes the main threat as cells of Al-Qaeda, ISIL and their affiliates, and records more than 3,000 departures of foreign fighters between 2000 and 2018.
- Terrorist financing response. Assessors rated the response substantial, with more than 1,700 terrorist financing investigations and over 1,100 convictions since 2013.
- Proliferation financing. The overall risk is medium-low: the direct threat is low and the indirect threat medium-low. No proliferation financing cases were found, though the assessment warns that this does not mean none exist.
- Most exposed channels. Banks are the most exposed sector, mainly through wire transfers and trade finance. Cross-border movement of goods and trade finance carry a medium-high residual risk.
Common typologies
- Commercial concealment (tasattur). Businesses registered to Saudi nationals but run by non-Saudis for their own account, often moving cash earnings abroad. In November 2025 alone the Ministry of Commerce carried out 4,242 inspections and found 98 suspected cases.
- Front companies and pass-through accounts. Commercial entities that collect funds from many parties and quickly transfer them abroad, or move money in circles between related accounts and companies, with no commercial reason.
- Nominees and third parties. Bank accounts or companies held in other people’s names, and intermediaries used to hide who is really behind a transaction.
- Cash, gold and illegal remittances. Unlicensed money transfer, and cash and gold carried across the border without being declared or falsely declared. Remittance outflows are large: about USD 38.8 billion in the year to April 2017.
- Trade-based money laundering. The 2018 evaluation found trade to be one of the main ways criminal proceeds leave the country.
- Fraud. Call-centre and impersonation scams. In one 2024 case, a network impersonating government agencies carried out 177 fraudulent operations worth SAR 22 million, and two members were jailed for 15 years each.
Red flags for front-line staff
These are drawn from the 2025 national risk assessment summary, the FATF evaluation and supervisors’ guidance. One red flag on its own is not proof of wrongdoing, but several together call for closer review and, where suspicion remains, an STR.
Business accounts
- Funds collected from many unrelated parties and quickly sent abroad
- International transfers soon after cash deposits, with no commercial basis
- Money moving in circles between related accounts and companies
- Turnover far above what the business could plausibly generate
Ownership and control
- Accounts or companies held in someone else’s name
- Intermediaries or third parties used to hide who is behind a transaction
- A non-Saudi employee who appears to run a business registered to a Saudi national
- Reluctance to explain the source of funds or who owns the business
Cash and gold
- Large cash deposits that do not match the customer’s profile
- Gold bought in cash just below SAR 50,000, or a purchase split into several payments
- Cash, gold or jewellery of SAR 40,000 or more taken across the border without a declaration
- Frequent cash exchanges or remittances with no clear purpose
Trade and proliferation
- Over- or under-invoiced goods, or goods described too vaguely to check
- Trade finance for dual-use goods
- Shipments routed through countries with weak export controls
- Counterparties linked to sanctioned countries or persons
Sources for this section (12)
- National ML Risk Assessment 2025, public summary (opens in a new tab)
- National PF Risk Assessment 2025, public summary (opens in a new tab)
- FATF and MENAFATF mutual evaluation report, 2018 (PDF) (opens in a new tab)
- Mutual evaluation, executive summary (PDF) (opens in a new tab)
- AML Permanent Committee: guidance and reports (opens in a new tab)
- Ministry of Commerce on the Anti-Commercial Concealment Law, 2020 (opens in a new tab)
- Ministry of Commerce on concealment inspections, December 2025 (opens in a new tab)
- SAMA circular on the suspicious commercial concealment index, 2021 (opens in a new tab)
- Zawya on the new border declaration threshold, June 2026 (opens in a new tab)
- Saudi Gazette on the impersonation fraud case, October 2024 (opens in a new tab)
- Argaam on the SAR 4 billion case, September 2022 (opens in a new tab)
- Saudi Gazette on the SAR 1.035 billion case, October 2023 (opens in a new tab)
Section 08
Official sources
The official documents and websites this pack is built from, grouped by type.
Standards and assessments
- FATF country profileAssessments, follow-up reports and membership (opens in a new tab)
- MENAFATFRegional body website (opens in a new tab)
- Mutual evaluation report, September 2018Joint FATF and MENAFATF report (PDF) (opens in a new tab)
- Follow-up report, 2020FATF re-ratings after the 2018 evaluation (opens in a new tab)
- FATF assessment calendarDates for the next evaluation (opens in a new tab)
- Mutual evaluation executive summaryKey findings and ratings (PDF) (opens in a new tab)
- Saudi Arabia’s mutual evaluation pageAML Permanent Committee (opens in a new tab)
Laws and regulations
- Anti-Money Laundering LawConsolidated English text, AML Permanent Committee (opens in a new tab)
- AML Law amendment, April 2026Umm Al-Qura official gazette (opens in a new tab)
- AML Implementing Regulations, June 2026Umm Al-Qura official gazette (opens in a new tab)
- Law on Combating Crimes of Terrorism and its FinancingSAMA Rulebook (opens in a new tab)
- Counter-Terrorism Law amendments, June 2026Umm Al-Qura official gazette (opens in a new tab)
- Law on Management of Seized and Confiscated FundsUmm Al-Qura official gazette, 2026 (opens in a new tab)
- AML Law penaltiesArticles 26 to 31, SAMA Rulebook (opens in a new tab)
Supervisor rules and guidance
Authorities
Sanctions
Risk, guidance and red flags
- National ML Risk Assessment 2025Public summary, AML Permanent Committee (opens in a new tab)
- National PF Risk Assessment 2025Public summary, AML Permanent Committee (opens in a new tab)
- Guidance and reportsAML Permanent Committee (opens in a new tab)
- Suspicious commercial concealment indexSAMA circular, 2021 (opens in a new tab)
- Anti-Commercial Concealment LawMinistry of Commerce announcement, 2020 (opens in a new tab)
Official websites sometimes move documents. If a link no longer works, search the issuing body’s website for the document title. News reports and secondary summaries are cited at the end of each section.
Section 09
Test yourself
Eight scenarios for a self-check. Choose your answer mentally or note it down, then reveal the explanation. Count your own correct answers; no score or learning progress is saved.
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Question 1. A jeweller in Riyadh sells gold to a customer for SAR 55,000 in cash. What applies?
- Nothing, because gold dealers are not covered
- The sale is a cash transaction of SAR 50,000 or more, so customer due diligence and ten-year record keeping apply
- Only a border declaration is needed
- The sale must be reported to SAFIU automatically, whatever the circumstances
Show answer
Answer: B. Dealers in gold, precious metals and stones are covered when they carry out a cash transaction with a customer of SAR 50,000 or more. An STR is needed only if the jeweller suspects money laundering or terrorist financing, but the records must be kept for at least ten years.
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Question 2. How long must customer due diligence records be kept?
- Five years
- Seven years
- At least ten years after the relationship ends
- Only until the account is closed
Show answer
Answer: C. The AML Law requires customer due diligence records to be kept for at least ten years after the relationship ends, and transaction records for at least ten years after the transaction or account closure. That is twice the FATF minimum.
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Question 3. When must a suspicious transaction report (STR) be filed with SAFIU?
- Immediately and directly, whatever the amount
- Within five working days
- Only for transactions above SAR 50,000
- After the customer has been asked to explain
Show answer
Answer: A. The AML Law requires STRs to be filed immediately and directly once suspicion arises, whatever the amount. Asking the customer to explain could tip them off, which the law prohibits.
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Question 4. A traveller arrives in Jeddah carrying SAR 45,000 in cash and gold jewellery. What must they do?
- Nothing, because the threshold is SAR 60,000
- Declare the cash only
- Declare it only if a customs officer asks
- Declare it to ZATCA, because the threshold has been SAR 40,000 since June 2026
Show answer
Answer: D. The updated AML regulations lowered the declaration threshold from SAR 60,000 to SAR 40,000 in June 2026. It covers cash, bearer instruments, gold, precious metals, gems and jewellery, and a first breach can bring a fine of 10% to 25% of the value.
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Question 5. Which body supervises real estate brokers for AML/CFT purposes?
- The Ministry of Commerce
- The Real Estate General Authority (REGA)
- The Saudi Central Bank (SAMA)
- The Ministry of Justice
Show answer
Answer: B. REGA supervises licensed real estate brokers under the Real Estate Brokerage Law. The Ministry of Commerce supervises dealers in precious metals and stones and accountants, and the Ministry of Justice supervises lawyers.
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Question 6. A bank finds that a new customer exactly matches a name just added to the national list of designated persons. What should it do?
- Ask the customer to explain the match
- Wait for its internal compliance committee to approve a freeze
- Close the account and return the funds
- Freeze the funds within hours, without prior notice, and notify SAMA within five working days
Show answer
Answer: D. SAMA’s guide requires firms to freeze promptly, within hours and without telling the customer, and to notify SAMA within five working days. The CMA’s rules make clear that a freeze cannot wait for internal approval.
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Question 7. A company’s records show a Saudi national as its sole owner, but a non-Saudi manager controls all its accounts and moves the cash takings abroad. What does this suggest?
- Possible commercial concealment (tasattur), which should be reported to SAFIU if suspicion remains
- Normal practice for a family business
- A matter for the tax authority only
- Nothing, because the official records are conclusive
Show answer
Answer: A. Businesses run by non-Saudis behind a Saudi national’s name are a key Saudi risk, often linked to cash moved abroad. Treat the records as one source, check who really controls the business, and file an STR if suspicion remains.
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Question 8. How did the 2025 national risk assessment summary rate Saudi Arabia’s overall money laundering risk?
- Low
- High
- Medium
- Very high
Show answer
Answer: C. The 2025 summary rates the overall money laundering risk as medium, with drug trafficking, corruption, cross-border smuggling and fraud as the highest threats, and banks and gold dealers as the most exposed sectors. Proliferation financing risk is rated medium-low.
Reflect on your answers
- 7 or 8 correct: you have a strong grasp of Saudi Arabia’s regime.
- 5 or 6 correct: review section 4 on who must comply and section 5 on key obligations.
- 4 or fewer: start with the AML Foundations & Core Concepts course, then come back to this pack.
Keep learning
Build the foundations behind the pack.
Other country guides
Editorial update · 7 October 2026
Navigation and self-check instructions improved; ownership summaries clarified.
This update covers presentation and the wording noted above. It does not revalidate every legal statement. How to use the sources and review dates
This country guide is for general education and is not legal or regulatory advice. Always rely on the official source for compliance decisions.