--- title: "Saudi Arabia (SA) — Financial-Integrity Intelligence · Sentinel" canonical: https://sentinel.gi/jurisdictions/saudi-arabia/ source_html: /jurisdictions/saudi-arabia/index.html description: "Financial integrity intelligence for Saudi Arabia (SA): sanctions, beneficial ownership, enabler jurisdictions, conflict finance, digital assets and compliance technology — with sourced findings." generated_at: 2026-11-08T04:46:02Z content_sha256: 87841b594c200be0e09d73dfed4ea39890c4ef49b150d811810e4a9078035511 generator: "fe-fleet/md-twin@1.0" --- # Saudi Arabia (SA) — Financial-Integrity Intelligence · Sentinel Not every instrument is backed by its official text yet. At least one law or rulebook covered here has no official source (tier 1) retrieved for it yet. No finding on this page is shown with confidence above “Probable” until stronger sources are retrieved. Financial Integrity Monitor # Saudi Arabia SA Domains covered 7 of 8 Sources 173 Role actions 8 Horizon <90d 0 Jurisdiction profile FATF status: Compliant (Fatf Member Since June 2019; Not Grey-Listed; Remains In Enhanced Follow-Up Post-2018 Mutual Evaluation) Tier: B Risk direction: Stable Enablement vs enforcement: Mixed AML regime built on the 2003 Anti-Money Laundering Statute and Implementing Regulations, supervised by SAMA (banks/insurance/finance cos), CMA (securities) and SAFIU (FIU). More Legal AML framework assessed as robust in 2018 MER but CFT/effectiveness lagged; enhanced follow-up ongoing with partial re-ratings (R6, R7 upgraded to largely compliant). Crypto activity remains formally prohibited even as CBDC/tokenization pilots expand. Key deficiencies - No updated effectiveness assessment since 2018 MER; follow-up reports assess only technical compliance, leaving confiscation/asset-recovery and cross-border TF-disruption effectiveness gaps unverified - Historic SAFIU STR backlog (~30% at time of MER) and limited use of targeted financial sanctions to disrupt TF support beyond the Kingdom - No comprehensive VASP/crypto licensing framework despite rapid informal crypto-market growth, creating an unregulated grey zone - DPMS (precious metals/stones dealers) and money-remitter sectors flagged by SAMA/MER as highest ML risk with limited independent verification of current supervisory intensity - Limited public transparency of SAMA/CMA supervisory penalties compared to FinCEN/OFAC disclosure practice Recent developments (18m) - FATF enhanced follow-up process continues; Saudi Arabia remains compliant on 17/40 and largely compliant on 21/40 FATF Recommendations, partially compliant on 2 - FSB 2025 thematic review classifies Saudi Arabia (with China) among six jurisdictions maintaining outright prohibition on cryptoasset activities - SAMA/CMA advanced tokenization, CBDC pilots and scoped DeFi-adjacent innovation through 2025 while maintaining the formal crypto prohibition - CMA fully liberalized foreign portfolio investor access to the Saudi capital market (January 2026), removing the $500m AUM qualification threshold - OFAC sustained a high tempo of Houthi-network sanctions actions (crypto wallets, petroleum smuggling, shipping fronts) directly implicating Saudi Arabia's Red Sea security and financial-crime exposure as principal target - Nazaha (Oversight and Anti-Corruption Authority) continued periodic mass arrest rounds of public officials for bribery/embezzlement/money laundering Brief ## Lead signal #### Lead Signal Saudi Arabia's financial integrity architecture continues to mature through standing instruments rather than through any single new enforcement event this cycle. The beneficial ownership regime shifted meaningfully on 4 January 2026, when the Ministry of Commerce's new rules under Ministerial Decision 267 (issued 26 November 2025) took effect, applying a three-tier ultimate beneficial owner test, 25 percent ownership, effective control, or a manager, board member, or chairman standing in that capacity, across most company forms. Independent legal commentary corroborates the instrument number, effective date, and test design, although a primary Ministry of Commerce gazette text has not yet been retrieved to confirm the operative detail directly. This development is read as probable rather than confirmed accordingly, and it addresses a disclosure deficiency the Kingdom's 2018 mutual evaluation had previously flagged. Read full brief #### Lead Signal Saudi Arabia's financial integrity architecture continues to mature through standing instruments rather than through any single new enforcement event this cycle. The beneficial ownership regime shifted meaningfully on 4 January 2026, when the Ministry of Commerce's new rules under Ministerial Decision 267 (issued 26 November 2025) took effect, applying a three-tier ultimate beneficial owner test, 25 percent ownership, effective control, or a manager, board member, or chairman standing in that capacity, across most company forms. Independent legal commentary corroborates the instrument number, effective date, and test design, although a primary Ministry of Commerce gazette text has not yet been retrieved to confirm the operative detail directly. This development is read as probable rather than confirmed accordingly, and it addresses a disclosure deficiency the Kingdom's 2018 mutual evaluation had previously flagged. Alongside the ownership-transparency shift, the underlying anti-money-laundering and counter-terrorist-financing framework remains anchored by the AML Law as amended by Royal Decree D/223 of 15 April 2026, together with the Saudi Central Bank's Circular 472035766 and the Capital Market Authority's Resolution 4-163-2025 implementing targeted financial sanctions, both confirmed in force by direct regulator rulebook sources. Saudi Arabia remains off the Financial Action Task Force's black and grey lists, continuing instead in enhanced follow-up since its 2018 evaluation, with a fifth-round onsite assessment currently scheduled around November 2026. #### Other Developments Beneficial ownership rule broadens disclosure base. The three-tier ownership and control test introduced by Ministerial Decision 267 extends beyond simple shareholding thresholds to capture individuals exercising effective control or serving in senior management or board capacities, a structural widening of the pool of persons a company must identify and disclose as part of its ownership record. Standing sanctions-implementation architecture confirmed current. Both the Saudi Central Bank and the Capital Market Authority maintain dedicated targeted financial sanctions implementation rules, issued in December 2025 and confirmed in force through direct regulator publication, giving banks, investment firms, and cross-sector obliged entities a documented basis for sanctions screening obligations tied to Financial Action Task Force Recommendations 6, 7, 2, 18, and 21. Terrorism-designation legislation in the regional background. Draft legislation approved on 11 October 2026 by Yemen's internationally recognised government would designate the Houthi movement a terrorist organisation, following an attack on Riyadh's airport. This sits as conflict-finance and sanctions-nexus background context relevant to correspondent banking exposure, though no new Saudi-specific designation action fell within the current reporting window. #### Cross-Monitor Connections The beneficial ownership tightening under Ministerial Decision 267 has direct relevance to corporate-transparency and company-formation oversight tracked elsewhere in the fleet, since a broadened ownership-disclosure test changes what due diligence on Saudi corporate structures can reasonably rely upon. The Yemen terrorism-designation legislation, while outside this window's direct sanctions-action scope for Saudi Arabia itself, is the kind of conflict-finance development that correspondent-banking and cross-border-payment monitoring should track for downstream screening implications, given the shared regional exposure. #### Outlook The most consequential near-term marker is the scheduled fifth-round Financial Action Task Force and Middle East and North Africa Financial Action Task Force mutual evaluation, with an onsite assessment expected around November 2026 and a possible plenary discussion around June 2027, as scheduled. Continued incremental tightening of the ownership-transparency and targeted-financial-sanctions architecture ahead of that assessment would be consistent with the pattern observed since the 2018 evaluation. Confirmation of the underlying implementing regulation text for the April 2026 AML Law amendments, beyond the decree register and secondary commentary currently available, remains an open item for future verification. Earlier periodic briefs (4) 25 Oct 2026 · fim-2026-10-25 #### Lead Signal Saudi Arabia's financial integrity architecture continues to mature through standing instruments rather than through any single new enforcement event. The beneficial ownership regime shifted meaningfully on 4 January 2026, when the Ministry of Commerce's new rules under Ministerial Decision 267 (issued 26 November 2025) took effect, applying a three-tier ultimate beneficial owner test, 25 percent ownership, effective control, or a manager, board member, or chairman standing in that capacity, across most company forms. Independent legal commentary corroborates the instrument number, effective date, and test design, although a primary Ministry of Commerce gazette text has not yet been retrieved to confirm the operative detail directly. This development is read as probable rather than confirmed accordingly, and it addresses a disclosure deficiency the Kingdom's 2018 mutual evaluation had previously flagged. Alongside the ownership-transparency shift, the underlying anti-money-laundering and counter-terrorist-financing framework remains anchored by the AML Law as amended by Royal Decree D/223 of 15 April 2026, together with the Saudi Central Bank's Circular 472035766 and the Capital Market Authority's Resolution 4-163-2025 implementing targeted financial sanctions, both confirmed in force by direct regulator rulebook sources. Saudi Arabia remains off the Financial Action Task Force's black and grey lists, continuing instead in enhanced follow-up since its 2018 evaluation, with a fifth-round onsite assessment currently scheduled around November 2026. #### Other Developments Beneficial ownership rule broadens disclosure base. The three-tier ownership and control test introduced by Ministerial Decision 267 extends beyond simple shareholding thresholds to capture individuals exercising effective control or serving in senior management or board capacities, a structural widening of the pool of persons a company must identify and disclose as part of its ownership record. Standing sanctions-implementation architecture confirmed current. Both the Saudi Central Bank and the Capital Market Authority maintain dedicated targeted financial sanctions implementation rules, issued in December 2025 and confirmed in force through direct regulator publication, giving banks, investment firms, and cross-sector obliged entities a documented basis for sanctions screening obligations tied to Financial Action Task Force Recommendations 6, 7, 2, 18, and 21. Terrorism-designation legislation in the regional background. Draft legislation approved on 11 October 2026 by Yemen's internationally recognised government would designate the Houthi movement a terrorist organisation, following an attack on Riyadh's airport. This sits as conflict-finance and sanctions-nexus background context relevant to correspondent banking exposure, though no new Saudi-specific designation action fell within the current reporting window. #### Cross-Monitor Connections The beneficial ownership tightening under Ministerial Decision 267 has direct relevance to corporate-transparency and company-formation oversight tracked elsewhere in the fleet, since a broadened ownership-disclosure test changes what due diligence on Saudi corporate structures can reasonably rely upon. The Yemen terrorism-designation legislation, while outside this window's direct sanctions-action scope for Saudi Arabia itself, is the kind of conflict-finance development that correspondent-banking and cross-border-payment monitoring should track for downstream screening implications, given the shared regional exposure. #### Outlook The most consequential near-term marker is the scheduled fifth-round Financial Action Task Force and Middle East and North Africa Financial Action Task Force mutual evaluation, with an onsite assessment expected around November 2026 and a possible plenary discussion around June 2027, as scheduled. Continued incremental tightening of the ownership-transparency and targeted-financial-sanctions architecture ahead of that assessment would be consistent with the pattern observed since the 2018 evaluation. Confirmation of the underlying implementing regulation text for the April 2026 AML Law amendments, beyond the decree register and secondary commentary currently available, remains an open item for future verification. 18 Oct 2026 · fim-2026-10-18 #### Lead Signal Operation Economic Outcast, the ongoing OFAC sanctions programme targeting Iranian military-procurement networks, expanded in late September and early October 2026 to designate entities located across Iran, China, Hong Kong, Pakistan, Saudi Arabia and Turkiye. The designation, made under Executive Order 13382 and Executive Order 13902, reached a Saudi Arabia-domiciled node of the network according to a law-firm summary of the action; the underlying Federal Register notice naming the specific Saudi Arabia entity has not been independently retrieved this cycle, so the precise identity and conduct of the entity remain probable rather than confirmed. The finding is significant less for what it says about Saudi Arabia as a jurisdiction and more for what it says about the geography of Iranian procurement intermediation: a multi-jurisdictional web in which Saudi Arabia appears as one transit or facilitation point among several, rather than as the primary target. Separately, Saudi Arabia confirmed a materially different cross-border financial-infrastructure posture than had been generally understood. The Saudi Central Bank (SAMA) stated that its participation in the mBridge multi-CBDC platform was a limited proof-of-concept trial that concluded on 13 May 2025 without progressing to further phases, and that SAMA did not continue into subsequent stages of the project. This clarification, surfacing in press commentary roughly sixteen months after the trial ended, narrows the jurisdiction's actual cross-border digital-asset footprint relative to earlier framing of Saudi Arabia as a full mBridge participant. #### Other Developments Cambodia's casino-sector enforcement sharpens, with no direct Saudi Arabia nexus but typological relevance. A nationwide audit of all 195 licensed Cambodian casinos in August 2026 produced 20 licence revocations, 29 suspensions and 23 lapses, followed by a sector-wide suspension of online and live-dealer betting from October 2026. Officials framed the action explicitly as preventing Cambodia from becoming a laundering base for technology-enabled criminal networks. This is a structural enforcement action in a jurisdiction that has previously been enablement-heavy, and it is tracked here as a comparator for how permissive gaming jurisdictions can pivot toward enforcement once typology pressure becomes visible. Saudi Arabia's FATF standing remains unchanged. Saudi Arabia is rated compliant on 17 of 40 FATF Recommendations and largely compliant on 21, with Recommendations 18 and 21 downgraded since the 2018 mutual evaluation. Saudi Arabia is not named in FATF's list of jurisdictions under increased monitoring. A possible onsite assessment under the 2022 Assessment Methodology is anticipated around November 2026, which would produce Saudi Arabia's first mutual evaluation under the newer methodology. #### Cross-Monitor Connections The OFAC designation's routing through a Saudi Arabia-domiciled entity is a sanctions-architecture signal that intersects with correspondent-banking exposure questions tracked elsewhere in the fleet: a network spanning Iran, China, Hong Kong, Pakistan, Saudi Arabia and Turkiye implies multiple banking relationships that correspondent institutions screening against OFAC's SDN list will need to reassess. SAMA's mBridge withdrawal is relevant to any digital-asset or payments-infrastructure tracker assessing the pace and durability of multi-CBDC corridor development; a confirmed, limited-scope withdrawal by a G20-adjacent central bank is a data point against overstating near-term multi-CBDC adoption momentum. #### Outlook The Saudi Arabia-specific element of the OFAC action will likely sharpen as the underlying Federal Register notice becomes available, which should permit a confirmed-tier assessment of the entity's identity and conduct in a future cycle. Saudi Arabia's FATF position is not expected to shift before the possible November 2026 onsite assessment; any change in rating or grey-list status would follow a Plenary discussion no earlier than mid-2027. On the digital-asset side, SAMA's clarified mBridge posture suggests any future cross-border CBDC engagement by Saudi Arabia would represent a fresh decision rather than a continuation of the 2025 pilot, and is worth monitoring for signs of re-engagement or formal confirmation of non-participation. 11 Oct 2026 · fim-2026-10-11 #### Lead Signal Saudi Arabia's financial-integrity architecture moved on two fronts this cycle, and both point the same direction: a deepening of the technical plumbing that connects the Kingdom's payment system to its sanctions and beneficial-ownership obligations. The Saudi Central Bank (SAMA) issued Circular No. 482028988, which took effect 1 October 2026 and mandates that payment systems and their operators integrate with the Security Council Resolutions Notification System. This is a structural finding, not an incident: it operationalises real-time screening against UN sanctions designations directly on payment rails, rather than leaving screening to periodic manual checks. The same architecture-over-incident reading applies to beneficial ownership. Three SAMA circulars issued across 2026 — in March, May and July — require payment licensees to integrate with Wathq, the Private Associations and Foundations inquiry service, and the General Authority for Awqaf verification service, so that ultimate beneficial owners can be verified against government registries rather than self-declared documentation. Taken together, these measures address a weakness flagged in Saudi Arabia's 2018 FATF mutual evaluation on beneficial-ownership implementation, and they land ahead of a possible FATF onsite assessment period in November 2026. A separate strand of this cycle's signal concerns the accuracy of secondary reporting on Saudi Arabia's FATF status. A Tier-4 aggregator asserted that Saudi Arabia underwent a FATF mutual evaluation with findings published in 2022. That claim is contradicted by FATF's own Tier-1 sources: the current black-and-grey list does not include Saudi Arabia, and FATF's assessment calendar records the last evaluation as adopted in September 2018, with a possible onsite period in November 2026 and a possible plenary discussion in June 2027. The disputed status is recorded as such rather than resolved in either direction, since the two source tiers are in direct conflict and only the primary FATF material carries the authority to settle it. 28 Sep 2026 · fim-2026-09-28 #### Lead Signal Saudi Arabia replaced its beneficial-ownership identification framework twice within a single regulatory cycle. The original UBO Rules, effective 3 April 2025, were superseded by Ministerial Decision No. 267 of 26 November 2025, effective 4 January 2026, which simplifies UBO identification to a three-tier test built around 25 percent-plus ownership, effective control, or a manager, board or chairman fallback. That replacement was followed by April 2026 Companies Law implementing regulations that mandate every Saudi-registered company to identify and disclose ultimate beneficial owners to the national Commercial Register, including the nature and extent of the qualifying interest and supporting documentation. Two independent Tier-3 law-firm sources agree on the sequence and dates, though no primary Ministerial Decision text or implementing-regulation text has yet been retrieved to corroborate the detail directly. Read together, the sequence points toward a decreasing corporate-opacity risk trajectory rather than a single isolated reform. A jurisdiction that first issues UBO rules, then replaces them with a simplified identification test, then layers a disclosure-to-register obligation across the whole corporate base within roughly twelve months, is moving its corporate-transparency architecture from episodic to structural. This is the kind of multi-step tightening that FATF Recommendation 24 assessments weigh heavily, and it sits alongside Saudi Arabia's confirmed status as a full FATF member since June 2019, not currently on the FATF grey list. #### Other Developments A single, unverified report of crypto-specific AML extension. One Tier-3 source describes a Capital Market Authority "Digital Asset Market Guidance" reportedly published in December 2025 that would extend AML obligations, including wallet-risk-register and source-of-wealth requirements, to crypto-asset exchanges, alongside a reported SAR 2.5 million fine issued in March 2026 against a local exchange for wallet-verification failures. This finding rests on one non-primary source with no corroboration this cycle and no primary CMA text retrieved; it is carried at Uncertain confidence and flagged for next-cycle primary-source verification rather than treated as an established regime feature. Institutional AML architecture confirmed as stable baseline. Saudi Arabia's AML/CTF regime continues to operate through the Saudi Central Bank (SAMA) for banks, the Capital Market Authority (CMA) for securities, and the Saudi Arabian Financial Intelligence Unit (SAFIU), which sits under the Presidency of State Security and functions as Saudi Arabia's Egmont Group node. This institutional map was corroborated across sources this cycle and represents the confirmed operating baseline against which the beneficial-ownership and crypto-sector developments above should be read. #### Cross-Monitor Connections The beneficial-ownership tightening sequence has direct bearing on corporate-vehicle risk assessments used elsewhere in the fleet: a jurisdiction moving toward Commercial Register-based UBO disclosure changes the calculus for enabler-jurisdiction and shell-structure typologies that route through Gulf corporate vehicles, even though no enabler-jurisdiction-specific signal for Saudi Arabia itself surfaced this cycle. The reported, unverified CMA digital-asset AML guidance is the kind of finding that, if corroborated, would warrant direct coordination with the crypto monitor's own module tracking; at Uncertain confidence and single-sourced, it does not yet support that connection being drawn with any weight. #### Outlook The near-term test is whether a primary Ministerial Decision No. 267 text or the April 2026 Companies Law implementing regulations become retrievable in primary form, which would allow the current Probable-confidence assessment of the UBO tightening to be upgraded. Equally material is whether the reported CMA Digital Asset Market Guidance is corroborated against a primary CMA publication; until it is, it remains a single-source, Uncertain-confidence watch item rather than a confirmed extension of AML obligations to the crypto sector. Saudi Arabia's underlying FATF-member, non-grey-listed status is not expected to change and provides the stable frame against which both of these developments should continue to be assessed. Domain intelligence (D1–D8) #### Sanctions Architecture and Evasion The D1 exposure of Saudi Arabia this cycle is defined by architecture rather than incident. Three sequential OFAC designation actions in the eighteen-month baseline window trace a single financial-infrastructure target rather than three unrelated events: a Houthi-linked cryptocurrency-wallet network in April 2025, involving eight Tron-network USDT wallets and Russia-based facilitators, moving close to one billion dollars with roughly two hundred million dollars cashed out to mainstream exchanges including exposure to the OFAC-sanctioned exchange Garantex; a petroleum-smuggling and sanctions-evasion network in July 2025, built around UAE-registered petroleum trading firms and exchange houses tied to Ansarallah; and a shipping and currency-exchange network in January 2026, centred on Albarraq Shipping Co and Yemen-based exchange and transfer companies. Read as architecture, this sequence demonstrates sustained rather than one-off enforcement tempo by the United States against Houthi financial infrastructure operating in the Red Sea and Yemen security environment immediately bordering Saudi Arabia, with Saudi Arabia positioned as the principal regional security target of an Iran-backed evasion and laundering network rather than as an enabling jurisdiction for it. Continue reading Running in parallel is a more equivocal signal: the FATF technical-compliance trajectory of Saudi Arabia itself. Under ongoing MENAFATF enhanced follow-up from the 2018 Mutual Evaluation, Recommendations 6 and 7, covering targeted financial sanctions, were upgraded from partially compliant to largely compliant, an improvement directly relevant to the capacity of the jurisdiction to screen and freeze assets connected to the Houthi networks described above. Concurrently, however, Recommendations 18 and 21, covering internal controls and tipping-off and confidentiality obligations, were downgraded from compliant to largely compliant. The net technical-compliance position stands at 17 of 40 Recommendations compliant, 21 largely compliant, and 2 partially compliant. Saudi Arabia has been a full FATF member since June 2019 and remains outside the FATF grey and black lists as of the most recent plenary updates; the enhanced follow-up standing of the jurisdiction is a distinct status from grey-listing and should not be conflated with it. The mixed technical-compliance trajectory carries an important caveat for architecture-level assessment: technical-compliance re-ratings, including the R.6 and R.7 upgrades, should not be read as evidence of improved AML and CFT effectiveness. The Saudi Arabian Financial Intelligence Unit carried an approximately 30 percent STR-processing backlog at the time of the 2018 Mutual Evaluation and demonstrated limited use of targeted financial sanctions to disrupt terrorist-financing support beyond the Kingdom; neither deficiency has been independently re-tested since 2018, and the concurrent R.18 and R.21 downgrade underscores that the technical-compliance trajectory is not unambiguously positive. Sanctions-regime divergence adds a further structural layer. The December 2025 update by the European Commission to the EU high-risk third-country AML and CFT list, adding Bolivia and the British Virgin Islands and delisting six other jurisdictions, left Saudi Arabia off the list entirely, consistent with its continued non-listing and its absence from the FATF grey list, and confirming convergence between the EU high-risk-third-country list and the UK Money Laundering Regulations advisory list on the status of Saudi Arabia specifically. That convergence sits alongside a separate and unresolved divergence: the United States, under Global Magnitsky authority in 2021, and the United Kingdom in 2020 each sanctioned approximately 17 to 20 Saudi nationals over the killing of Jamal Khashoggi, while the European Union adopted no equivalent designations despite establishing its own global human-rights sanctions regime in 2020. No delisting or convergence event on this point has been identified in the current window. Structurally, this domain illustrates the enablement-as-signal principle in an inverse register: rather than evaluating whether Saudi Arabia enables evasion, the material question this cycle is whether its financial perimeter is adequately defended against externally directed evasion activity. The sustained OFAC tempo, read against the mixed technical-compliance trajectory and the untested SAFIU effectiveness gap, suggests a defended perimeter under active external pressure rather than a fully settled one. #### Outlook The next MENAFATF enhanced follow-up report carries an indicative onsite window of November 2026 under the FATF assessments calendar, a date explicitly flagged as provisional and subject to adjustment; any further technical-compliance movement should be read against the persistent effectiveness-testing gap rather than as a freestanding improvement signal. The Houthi-network designation cadence maintained by OFAC has proceeded roughly every three to six months across the current window, and a further action within that cadence, whether targeting additional crypto-wallet infrastructure, petroleum-trading fronts, or shipping and exchange entities, would be consistent with the established pattern rather than a surprise. The unresolved EU and US-UK divergence on Khashoggi-related designations remains a standing watch item for any future EU adoption of parallel human-rights sanctions or any US or UK review of existing designees. #### Conflict Finance and Extractive-Industry Integrity Houthi war-economy financing directed at the security perimeter of Saudi Arabia is diversifying rather than simply continuing. The established revenue channel is illicit petroleum smuggling, sustained by a UAE-registered network of petroleum trading firms and exchange houses that OFAC designated in July 2025 under SDGT authority as linked to Ansarallah, and reinforced by the January 2026 OFAC designation of Houthi shipping and currency-exchange entities, including Albarraq Shipping Co and Yemen-based exchange and transfer companies. This petroleum-smuggling architecture has been assessed as sustaining an illicit oil-revenue stream that supports missile and drone attacks affecting Saudi territory and Red Sea shipping lanes, positioning the Houthi financial apparatus as a persistent conflict-finance threat directed at the border and maritime security of Saudi Arabia itself rather than at a third state. Continue reading The new development this cycle is the emergence of a second channel. Following the collapse of the Assad-era Captagon production base in Syria, Yemeni authorities allege that the Houthi movement is increasingly turning to narcotics trafficking, routed through Saudi Arabia and Gulf states and concealed within commercial and agricultural cargo shipments, to finance military operations. This allegation derives from a single tier-2 source category and has not been independently corroborated by a second source category this cycle, though it is pattern-consistent with documented regional trafficking-route shifts following the collapse of the Syrian production base, and it compounds an already-substantial petroleum-smuggling revenue base rather than replacing it. Applying the F4 conflict-finance filter source-channel-deployment trace clarifies the structure of both channels. The source, in each case, is illicit commodity or narcotics revenue generated substantially outside formal Saudi jurisdiction, in Houthi-controlled territory or through regional trafficking networks. The channel runs, for the petroleum stream, through petroleum-trading firms and exchange-house structures registered in third jurisdictions including the UAE, and for the emerging narcotics stream, through trade-finance and corporate fronts using commercial and agricultural cargo documentation as cover. The deployment, in both cases, is military: financing missile, drone, and broader Ansarallah operational capability directed, in significant part, at Saudi territory and its Red Sea shipping lanes. This is a domain in which Saudi Arabia functions exclusively as a target jurisdiction of conflict-finance flows rather than as a source or an enabling transit point, consistent with the broader D1 finding that the principal exposure of Saudi Arabia in the Houthi-network architecture is as a security target rather than as a facilitator of it. The active-scheme inventory catalogues the Captagon and narcotics-trafficking channel as a distinct scheme from the established petroleum-smuggling channel, with a red-flag indicator centred on narcotics concealed within commercial and agricultural cargo shipments layered through legitimate-looking trade fronts, observable principally through trade-documentation review rather than transaction monitoring alone. This gives trade-finance and corporate-sector compliance functions handling Gulf agricultural or commercial trade counterparties a concrete, if still single-source, indicator to weigh alongside the better-established petroleum-smuggling typology, for which screening obligations already attach under Executive Order 13224 and SDGT authority for banks and payment companies with exposure to the designated entities. This domain also illustrates the three-pillar balance principle in practice. Both revenue channels are properly read as counter-terrorist-financing rather than conventional AML signal: the deployment purpose is explicitly military and operational, not personal enrichment, and the F4 filter accordingly routes this material toward CTF-specific screening and SAR-trigger logic rather than generic AML transaction-monitoring frameworks, even where the underlying typologies, trade-based layering and cargo-document fraud, resemble conventional trade-based money-laundering patterns. #### Outlook The trajectory in this domain is assessed as deteriorating rather than stable, reflecting the addition of a narcotics-trafficking revenue channel to an already-established petroleum-smuggling base rather than any change in the underlying petroleum-smuggling picture itself. Corroboration of the Captagon-trafficking allegation from a second source category, whether regional law-enforcement reporting, a UN Panel of Experts finding, or additional investigative-journalism reporting, would be the most consequential near-term development for confirming or narrowing the materiality of this channel. Absent that corroboration, the narcotics-trafficking channel should continue to be treated as an assessed rather than high-confidence addition to the Houthi war-economy financing picture, and continued OFAC designation activity against petroleum-smuggling and shipping infrastructure remains the more probable near-term development given the established three-to-six-month designation cadence observed across this window. #### Crypto, Digital Assets, and Financial Innovation The own crypto-asset regulatory posture of Saudi Arabia, not global standard-setting activity, is the primary subject matter for the D5 profile of this jurisdiction. The November 2025 thematic review by the Financial Stability Board grouped Saudi Arabia with China among six jurisdictions maintaining a cryptoasset-activity prohibition, a classification that, read at face value, would place Saudi Arabia among the most restrictive crypto regimes globally. Independent legal analysis corroborated this cycle indicates that characterization overstates the actual scope of the restriction: the restriction applies to banks and other regulated financial institutions facilitating crypto transactions, not to individual ownership or peer-to-peer use, a materially narrower posture than the prohibition model applied in China. This distinction matters directly for firms assessing Saudi counterparty and market exposure: a bank-facing restriction leaves individual and offshore-routed crypto activity outside supervisory visibility, a different risk profile than a blanket ban would present, and one more consistent with a capacity gap in retail-level supervision than with a deliberate policy of comprehensive prohibition. Continue reading That formal restriction coexists with active innovation at the regulator level. SAMA and the Capital Market Authority continued to advance tokenization initiatives, central bank digital currency pilots, and scoped DeFi-adjacent innovation through 2025, a structural D5 and D6 crossover in which formal restriction on bank-facilitated crypto activity runs in parallel with regulator-led digital-asset infrastructure development. No licensed local virtual-asset service provider or centralized-exchange framework currently exists in Saudi Arabia, meaning that the gap between the bank-facing restriction and rapid informal or offshore adoption is not currently closed by any domestic licensing regime. The clearest illustration of the risk this supervisory gap presents comes from outside the domestic retail market of Saudi Arabia but directly within its security environment: the April 2025 OFAC designation of a Houthi-linked cryptocurrency-wallet network showed close to one billion dollars in Tron-network USDT flows tied to Russia-based facilitators, with roughly two hundred million dollars cashed out to mainstream exchanges, including exposure to the OFAC-sanctioned exchange Garantex, reportedly used to procure Russian-origin commodities and weapons and to launder proceeds connected to stolen Ukrainian grain. While this network is not itself a Saudi-domiciled scheme, its operation in the Red Sea and Yemen security environment immediately bordering Saudi Arabia demonstrates the cash-out capability that unlicensed, offshore-routed crypto infrastructure can provide to sanctioned actors operating near a jurisdiction whose own domestic crypto-asset supervision remains narrower in practice than its headline classification suggests. The active-scheme inventory catalogues this Houthi crypto-financial network with two red-flag indicators of direct relevance to crypto-asset operators and money-service businesses: high-volume Tron-network USDT wallet transfers linked to sanctioned facilitators and cashed out via mainstream exchanges and OTC brokers, an on-chain-observable indicator; and money-service businesses operating under legitimate-looking cover providing cash-out channels for sanctions-evasion proceeds, an onboarding-observable indicator. Both indicators are directly relevant to virtual-asset-service-provider and correspondent-banking due diligence for counterparties with exposure to the Gulf and Red Sea corridor, independent of the domestic licensing status of Saudi Arabia. This domain also functions as a live illustration of the three-pillar balance principle: the CTF-relevant Houthi crypto-wallet flow and the AML and CFT structural question of bank-facing restriction versus individual-level supervision sit alongside a CPF-relevant consideration, namely whether the parallel SAMA CBDC development could, if not carefully sequenced with VASP licensing, itself become a channel requiring proliferation-financing-aware design choices. No CPF-specific finding was identified this cycle, but the structural trajectory of this domain, formal restriction, informal growth, and regulator-led innovation proceeding in parallel, warrants continued three-pillar attention rather than an AML-only or CTF-only read. #### Outlook The most consequential near-term development for this domain would be any move from the current bank-facing restriction toward a licensed virtual-asset service provider or crypto-asset service provider regime, which would extend registration and travel-rule-type obligations to a currently unregulated segment and narrow the gap between formal restriction and informal adoption growth. Continued CBDC pilot maturation by SAMA is a parallel watch item, relevant less for its direct AML and CFT content than for what it signals about the pace of Saudi digital-asset infrastructure development relative to the pace of retail-level crypto-asset supervision. Absent a shift toward licensing, the coexistence of formal bank-facing restriction and unsupervised individual or offshore activity is likely to remain the defining structural feature of the D5 profile of Saudi Arabia. #### AML/CTF Regime Saudi Arabia's anti-money-laundering and counter-terrorist-financing architecture rests on a confirmed, in-force set of instruments: the AML Law (Royal Decree M/20, 1439H) as amended by Royal Decree D/223 of 15 April 2026, together with dual targeted financial sanctions implementing rules issued separately by the Saudi Central Bank, under Circular 472035766, and the Capital Market Authority, under Resolution 4-163-2025 of December 2025. Both regulator rulebook pages and the decree register directly confirm the instrument numbers and dates, giving this standing finding a confirmed-confidence rating. These implementing rules give banks, investment firms, and cross-sector obliged entities a documented basis for screening obligations that map onto Financial Action Task Force Recommendations 6 and 7 on targeted financial sanctions related to terrorism and proliferation financing, Recommendation 2 on national cooperation, Recommendation 18 on internal controls, and Recommendation 21 on tipping-off protections. Continue reading Against this standing architecture, Saudi Arabia's broader international standing remains unchanged this cycle: the Kingdom is not on the Financial Action Task Force's black list or grey list, nor is it named on the European Union's list of high-risk third countries, but it remains in enhanced follow-up status since its 2018 mutual evaluation. A fifth-round onsite assessment is currently scheduled around November 2026, with a possible plenary discussion around June 2027, as scheduled, representing the next major checkpoint for the jurisdiction's compliance trajectory. The combination of continuous follow-up reporting and a now-approaching fifth-round evaluation suggests an active, structurally embedded engagement with the Financial Action Task Force process rather than a static or passive compliance posture. A conflict-finance and sanctions-nexus development sits in the regional background this cycle: draft legislation approved on 11 October 2026 by Yemen's internationally recognised government would designate the Houthi movement a terrorist organisation, following an attack on Riyadh's airport. While this is not a Saudi-specific sanctions action and no corresponding Saudi Central Bank or Capital Market Authority designation fell within the current window, it is the kind of development that correspondent banks operating cross-border payment corridors into the Gulf region should track, given the potential downstream implications for terrorist-financing screening obligations under the Kingdom's existing targeted financial sanctions rules. One gap worth noting for completeness: no primary text of the implementing regulations accompanying the April 2026 AML Law amendments has yet been located beyond the Royal Decree register entry and secondary legal commentary describing the amendments as touching five articles and adding one new one. This leaves the precise operative detail of the April 2026 amendment package somewhat less fully verified than the headline fact of the amendment's existence and date. #### Outlook The fifth-round Financial Action Task Force and Middle East and North Africa Financial Action Task Force mutual evaluation, with an onsite assessment scheduled around November 2026, is the dominant near-term marker for this regime. Industry expectation in the region continues to anticipate further tightening of beneficial ownership and designated non-financial business and profession supervision ahead of that evaluation cycle. Locating primary implementing-regulation text for the April 2026 AML Law amendment would strengthen confidence in the operative detail of the current regime, and continued monitoring of the Yemen-related terrorism-designation legislation for any downstream Saudi-specific sanctions or screening implications is warranted given the shared regional exposure. Baseline-Tracked Domains with No Current-Cycle Escalation (1 of 8) - D8 Commercial Activity: Standing coverage — no activity this cycle. Regulatory horizon Proposed 2027-Q2 · ±half_year ### Saudi Arabia 5th-round FATF-MENAFATF mutual evaluation A possible onsite assessment period is scheduled around November 2026, with a possible plenary discussion around June 2027. [Source](https://www.fatf-gafi.org/en/calendars/assessments.html) Proposed 2027-Q2 · ±half_year ### FATF 5th-round mutual evaluation of Saudi Arabia A possible onsite assessment in November 2026 with a possible Plenary discussion in June 2027 would produce SA's first mutual evaluation under the 2022 Methodology. [FATF / MENAFATF Source](https://www.fatf-gafi.org/en/calendars/assessments.html) 2 dated · 3 pending date · baseline financial-integrity-2026-07-05 Role action cards MLRO ### Saudi beneficial ownership rules broadened the UBO test to capture effective control and senior management, not just shareholding, effective January 2026. Customer due diligence files on Saudi corporate clients built solely on shareholding registers may now be incomplete under the three-tier test, and reportable-activity thresholds tied to ownership verification should be reviewed against the broader test. 1 evidence refs Compliance ### Standing targeted financial sanctions implementation rules from the Saudi Central Bank and Capital Market Authority remain in force and confirmed via direct regulator sources. Policy frameworks referencing Saudi sanctions-screening obligations can continue to cite Circular 472035766 and Resolution 4-163-2025 as the current controlling instruments pending the fifth-round mutual evaluation. 1 evidence refs Board ### Saudi Arabia's fifth-round FATF mutual evaluation is now scheduled with an onsite assessment expected around November 2026. This is the most consequential near-term marker for the Kingdom's financial-crime compliance standing, and recent beneficial-ownership and sanctions-architecture tightening should be read as preparation for that review. 2 evidence refs Risk ### A Yemen-origin Houthi terrorism-designation legislative development sits as regional conflict-finance background, without a corresponding new Saudi-specific sanctions action this cycle. Exposure concentration in correspondent banking channels touching the Gulf region should be monitored for downstream screening implications, though no immediate Saudi action has followed. 1 evidence refs Audit ### Primary-source implementing-regulation text for the April 2026 AML Law amendment has not yet been located, leaving the operative detail evidenced only by decree register and secondary commentary. Control-testing scope relying on the precise operative detail of the April 2026 amendment package should note this sourcing gap pending primary-text confirmation. 1 evidence refs Scenario sketches ### AMLA Transition and Cross-Border Supervisory Divergence As the European Union's Anti-Money Laundering Authority moves toward direct and indirect supervision of cross-border obliged entities under the AMLA Regulation, alongside the directly applicable AML Regulation and per-state transposition of the sixth AML Directive, a plausible structural effect is a widening gap between how ownership-transparency and sanctions-screening obligations are supervised within the European perimeter versus in autonomous jurisdictions such as Saudi Arabia that develop their own beneficial-ownership and targeted-financial-sanctions architecture independently. Correspondent banks and cross-border intermediaries bridging both regimes could face an increasingly complex task of reconciling a harmonising European Union-level standard with Saudi Arabia's own evolving, Financial Action Task Force-aligned but separately administered framework. This is an illustrative structural possibility, not an observed development. Illustrative scenario for analytical orientation only. Not compliance advice, not a prediction, and not a statement of observed fact. Standing trackers (T1–T6) Tracker Status Note T1 · Russian Sanctions-Evasion Architecture no_change T2 · EU AML Package / AMLA no_change T3 · FATF Grey List no_change T4 · Beneficial-Ownership Register Status no_change T5 · Crypto / VASP Regulatory Framework no_change T6 · Sanctions Regime Divergence no_change Registers ### Enforcement actions - 2 Apr 2025 - 22 Jul 2025 - 16 Jan 2026 - 28 Mar 2025 - 1 Mar 2026 - 1 Mar 2026 - 1 Mar 2026 - OFAC designated a network of individuals, exchange houses, and shipping/trading entities facilitating Houthi petroleum smuggling and sanctions evasion, directly implicating the Red Sea/Gulf security environment in which Saudi Arabia is the principal regional target. 22 Jul 2025 - OFAC increased pressure on Houthi smuggling and illicit revenue-generation networks, designating shipping companies (e.g., Albarraq Shipping Co) and Yemen-based exchange/transfer companies under Executive Order 13224. 16 Jan 2026 - OFAC sanctioned a Houthi financial-facilitator network including Russia-based operatives (Hushang and Sohrab Ghairat) and designated eight cryptocurrency wallets that moved close to $1 billion, used to procure Russian commodities/weapons and launder proceeds from stolen Ukrainian grain destined for Houthi-controlled territory near Saudi Arabia's southern border. 2 Apr 2025 - OFAC updated the SDGT designation of a Saudi-born individual (POB Medina, holder of a Saudi passport/national ID) as part of a broader action targeting a Hizballah finance-team sanctions-evasion network, adding secondary-sanctions risk information under the amended Executive Order 13224 framework. 28 Mar 2025 ### Sanctions changes - 2 Apr 2025 - 22 Jul 2025 - 16 Jan 2026 - 4 Dec 2025 - 1 Oct 2026 - 29 Sep 2026 - OFAC designated eight cryptocurrency wallets and associated facilitators tied to Houthi financial networks operating adjacent to Saudi Arabia's Red Sea security perimeter, part of sustained US pressure on Iran-backed Ansarallah financial infrastructure. 2 Apr 2025 - OFAC designated a Houthi-linked petroleum smuggling and sanctions-evasion network, including UAE-registered trading entities, as part of continuing efforts to cut off Houthi revenue streams that fund attacks affecting Saudi Arabia and Red Sea shipping. 22 Jul 2025 - The European Commission's December 2025 update to the EU high-risk third-country AML/CFT list (Delegated Regulations (EU) 2026/46 and 2026/83) added Bolivia and the British Virgin Islands while delisting Burkina Faso, Mali, Mozambique, Nigeria, South Africa and Tanzania; Saudi Arabia was not added to, nor was it previously on, this list, consistent with its absence from the FATF grey list. 4 Dec 2025 ### Regulatory horizon (register) - New Saudi Enforcement Law bills-of-exchange registration requirement - New Saudi Enforcement Law bills-of-exchange registration requirement - Companies Law implementing regulations (BO disclosure to Commercial Register) - FATF 5th-round mutual evaluation of Saudi Arabia - Saudi Arabia 5th-round FATF-MENAFATF mutual evaluation - FATF/MENAFATF 5th-round mutual evaluation of Saudi Arabia - Next MENAFATF/FATF enhanced follow-up report for Saudi Arabia - Potential evolution of Saudi Arabia's crypto prohibition toward licensed VASP framework - Continued Saudi capital-market foreign-ownership liberalization under Vision 2030 ### Active schemes - Houthi Red Sea sanctions-evasion and crypto-financial network - Captagon/narcotics trafficking route financing Houthi war economy - DPMS and money-remitter trade-based laundering exposure - Sovereign wealth fund (PIF) opacity and immunity structuring Sources - [CMS Law](https://cms.law/en/sau/legal-updates/the-recent-changes-on-the-aml-law-what-you-need-to-know) - [Saudi Gazette](https://saudigazette.com.sa/article/660632) - [Decree Tech LLC (Umm Al-Qura gazette aggregator)](https://decreesa.com/p/515501/) - [Government of Saudi Arabia Official Gazette (via Lexis Middle East)](https://www.lexismiddleeast.com/gazette/SaudiArabia/2026_5155/en) - [Bryan Cave Leighton Paisner](https://www.bclplaw.com/en-US/events-insights-news/saudi-arabia-new-ultimate-beneficial-owner-ubo-rules-issued.html) - [FATF](https://www.fatf-gafi.org/en/countries/detail/Saudi-Arabia.html) - [UN Security Council Press](https://press.un.org/en/2025/sc16222.doc.htm) - [Asharq Al-Awsat](https://english.aawsat.com/business/5177822-saudi-arabia-tightens-oversight-precious-metals-gems-trade-curb-money-laundering) - [Gulf News](https://gulfnews.com/world/gulf/saudi/travelling-with-gold-saudi-arabia-has-lowered-its-declaration-threshold-1.500588710) - [Tookitaki](https://www.tookitaki.com/compliance-hub/money-laundering-in-saudi-arabia-new-digital-economy-brings-stricter-aml-rules) - [Riyadh Web3](https://riyadhweb3.com/guides/web3-licensing-guide/) - [https://cms.law/en/sau/legal-updates/the-recent-changes-on-the-aml-law-what-you-need-to-know](https://cms.law/en/sau/legal-updates/the-recent-changes-on-the-aml-law-what-you-need-to-know) - [https://rulebook.sama.gov.sa/en/entiresection/5400](https://rulebook.sama.gov.sa/en/entiresection/5400) - [https://rulebook.sama.gov.sa/en/implementing-regulation-anti-money-laundering-law-0](https://rulebook.sama.gov.sa/en/implementing-regulation-anti-money-laundering-law-0) - [https://www.fatf-gafi.org/en/countries/detail/Saudi-Arabia.html](https://www.fatf-gafi.org/en/countries/detail/Saudi-Arabia.html) - [https://amluae.com/what-are-fatf-blacklist-and-grey-list-countries/](https://amluae.com/what-are-fatf-blacklist-and-grey-list-countries/) - [https://www.clydeco.com/en/insights/2026/01/saudi-arabia-s-new-beneficial-owner-rules](https://www.clydeco.com/en/insights/2026/01/saudi-arabia-s-new-beneficial-owner-rules) - [https://www.bclplaw.com/en-US/events-insights-news/saudi-arabia-new-ultimate-beneficial-owner-ubo-rules-issued.html](https://www.bclplaw.com/en-US/events-insights-news/saudi-arabia-new-ultimate-beneficial-owner-ubo-rules-issued.html) - [https://ofac.treasury.gov/recent-actions/20260116](https://ofac.treasury.gov/recent-actions/20260116) - [https://sanctionslawyers.net/economic-sanctions-programs/saudi-arabia/](https://sanctionslawyers.net/economic-sanctions-programs/saudi-arabia/) - [https://regmantle.com/blog/saudi.html](https://regmantle.com/blog/saudi.html) - [https://www.mondaq.com/saudiarabia/contracts-and-commercial-law/1736690/corporate-transparency-beneficial-ownership-disclosure-under-saudi-aml-law-what-companies-must-know-in-2026](https://www.mondaq.com/saudiarabia/contracts-and-commercial-law/1736690/corporate-transparency-beneficial-ownership-disclosure-under-saudi-aml-law-what-companies-must-know-in-2026) - [https://www.fatf-gafi.org/en/pages/frequently-asked-questions.html](https://www.fatf-gafi.org/en/pages/frequently-asked-questions.html) - [https://www.aml.gov.sa/en-us/Pages/MutualEvaluation.aspx](https://www.aml.gov.sa/en-us/Pages/MutualEvaluation.aspx) - [https://www.fluxforce.ai/jurisdictions/saudi-arabia](https://www.fluxforce.ai/jurisdictions/saudi-arabia) - [https://www.gibsondunn.com/publication-of-ultimate-beneficial-ownership-rules-in-saudi-arabia/?pdf=display](https://www.gibsondunn.com/publication-of-ultimate-beneficial-ownership-rules-in-saudi-arabia/?pdf=display) - [https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [https://www.fatf-gafi.org/en/calendars/assessments.html](https://www.fatf-gafi.org/en/calendars/assessments.html) - [https://www.arabnews.com/business/saudi-fintech-barq-becomes-kingdoms-newest-unicorn-after-3295m-funding-round-3001921](https://www.arabnews.com/business/saudi-fintech-barq-becomes-kingdoms-newest-unicorn-after-3295m-funding-round-3001921) - [https://rulebook.sama.gov.sa/en/payment-systems-and-payment-services-providers-circulars](https://rulebook.sama.gov.sa/en/payment-systems-and-payment-services-providers-circulars) - [https://www.legal500.com/intelligence/saudi-arabia/finance-and-banking/sama-issues-revised-oversight-framework-for-payment-systems](https://www.legal500.com/intelligence/saudi-arabia/finance-and-banking/sama-issues-revised-oversight-framework-for-payment-systems) - [https://cointelegraph.com/news/saudi-arabia-exits-china-backed-mbridge-cbdc-project-ft](https://cointelegraph.com/news/saudi-arabia-exits-china-backed-mbridge-cbdc-project-ft) - [https://nexiant.ai/resources/blogs/fatf-gcc-mutual-evaluation-status/](https://nexiant.ai/resources/blogs/fatf-gcc-mutual-evaluation-status/) - [FATF/MENAFATF](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofthekingdomofsaudiarabia.html) - [FATF](https://www.fatf-gafi.org/en/calendars/assessments.html) - [FATF](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-june-2026.html) - [Herbert Smith Freehills Kramer](https://www.hsfkramer.com/notes/sanctions/2026-posts/ofac-expands-operation-economic-outcast-with-actions-targeting-iranian-procurement-industry-and-sanctions-evasion) - [Forbes](https://www.forbes.com/sites/digital-assets/2026/09/28/saudi-arabia-left-the-worlds-biggest-cbdc-platform-sixteen-months-ago-it-took-the-ft-to-notice/) - [GGRAsia](https://www.ggrasia.com/cambodia-to-widen-casino-inspections-in-crackdown-on-illegal-online-gambling) - [The Cambodia Daily](https://english.cambodiadaily.com/2026/09/09/cambodia-to-suspend-online-gambling-at-all-casinos-from-october/) - [Saudi Anti-Money Laundering Permanent Committee (AMLPC)](https://www.aml.gov.sa/en-us/Pages/MutualEvaluation.aspx) - [FIRMCY (Ioannou & Sharpe LLC)](https://firm.cy/aml-country/saudi-arabia) - [Saudi Central Bank (SAMA) Rulebook](https://rulebook.sama.gov.sa/en/rules-implementation-targeted-financial-sanctions) - [Capital Market Authority (CMA)](https://cma.gov.sa/en/RulesRegulations/Circulars/Documents/Implementing_Rules_on_Targeted_Financial_Sanctions_en.pdf) - [DecreeSA (Royal Decree register)](https://decreesa.com/p/515501/) - [The Arab Weekly](https://thearabweekly.com/yemens-houthi-terror-designation-faces-test-reach-effectiveness) - [FIRMCY](https://firm.cy/aml-country/saudi-arabia) - [Mutual Evaluation of the Kingdom of Saudi Arabia](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationofthekingdomofsaudiarabia.html) - [Saudi Arabia](https://www.fatf-gafi.org/en/countries/detail/Saudi-Arabia.html) - [Mutual Evaluation of the United Arab Emirates (UAE) - Report and annexes](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Mutualevaluationoftheunitedarabemiratesuae-reportandannexes.html) - [Mutual Evaluations](https://www.fatf-gafi.org/en/publications/Mutualevaluations.html) - [Assessments](https://www.fatf-gafi.org/en/calendars/assessments.html) - [Middle East and North Africa Financial Action Task Force (MENAFATF)](https://www.fatf-gafi.org/en/countries/global-network/middle-east-and-north-africa-financial-action-task-force--menafa.html) - [Consolidated assessment ratings](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Assessment-ratings.html) - [Publications](https://www.fatf-gafi.org/en/publications.html) - [Consolidated Processes and Procedures for Mutual Evaluations and Follow-Up Universal Procedures](https://www.fatf-gafi.org/en/publications/Fatfgeneral/Universal-procedures.html) - [Outcomes of meetings](https://www.fatf-gafi.org/en/the-fatf/outcomes-of-meetings.html) - [Sanctions Programs and Country Information | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information) - [Archive of Changes to OFAC's Sanctions Lists | Office of Foreign Assets Control](https://ofac.treasury.gov/specially-designated-nationals-list-sdn-list/archive-of-changes-to-the-sdn-list) - [Recent Actions | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions) - [United Nations Security Council Consolidated List | Security Council](https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list) - [OFAC Related Press Releases | Office of Foreign Assets Control](https://ofac.treasury.gov/press-releases) - [Where is OFAC's Country List? What countries do I need to worry about in terms of U.S. sanctions? | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-programs-and-country-information/where-is-ofacs-country-list-what-countries-do-i-need-to-worry-about-in-terms-of-us-sanctions) - [Sanctions List Updates](https://ofac.treasury.gov/recent-actions/sanctions-list-updates) - [Counter Terrorism Designation | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20170427) - [Counter Terrorism Designations; Administrative List Updates: Addition of Secondary Sanctions Information | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250328) - [Sanctions List Service | Office of Foreign Assets Control](https://ofac.treasury.gov/sanctions-list-service) - [Saudi Arabia to Update Foreign Stock Ownership Limits Next Year - Bloomberg](https://www.bloomberg.com/news/articles/2025-10-30/saudi-arabia-to-update-foreign-stock-ownership-limits-next-year) - [BENEFICIAL OWNERSHIP OF LEGAL PERSONS MARCH 2023 MARCH 2023](https://www.fatf-gafi.org/content/dam/fatf-gafi/guidance/Guidance-Beneficial-Ownership-Legal-Persons.pdf.coredownload.pdf) - [Virtual Assets](https://www.fatf-gafi.org/en/publications/Virtualassets/Virtual-assets.html) - [Saudi Arabian Monetary Authority Adopts New Bond Issuance System Using Bloomberg | Press | Bloomberg LP](https://www.bloomberg.com/company/press/sama-bond-issuance-bloomberg/) - [Kingdom of Saudi Arabia](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/MER-Saudi-Arabia-2018.pdf) - [Saudi Arabia Opens Capital Market to All Foreign Investors - Bloomberg](https://www.bloomberg.com/news/articles/2026-01-06/saudi-arabia-opens-capital-market-to-all-foreign-investors) - [Directory of Open-Source Registries: Saudi Arabia](https://globenetwork.unodc.org/globenetwork/en/directory-of-open-source-registries/saudi-arabia.html) - [FATF ACADEMY](https://www.fatf-gafi.org/en/pages/FATF-academy.html) - [Updated Guidance for a Risk-Based Approach to Virtual Assets and Virtual Asset Service Providers](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-rba-virtual-assets-2021.html) - [The FATF Recommendations](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html) - [Saudi Arabia's progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fur-ksa-2020.html) - [Civil Penalties and Enforcement Information | Office of Foreign Assets Control](https://ofac.treasury.gov/civil-penalties-and-enforcement-information) - [Home](https://www.fatf-gafi.org/en/home.html) - [Jurisdictions under Increased Monitoring - 24 October 2025](https://www.fatf-gafi.org/en/publications/High-risk-and-other-monitored-jurisdictions/increased-monitoring-october-2025.html) - [Enforcement Actions | FinCEN.gov](https://www.fincen.gov/news/enforcement-actions) - [FATF releases detailed guidance to help practitioners recover criminal assets](https://www.fatf-gafi.org/en/publications/Methodsandtrends/asset-recovery-guidance-best-practices-2025.html) - [OFAC Sanctions Houthi Network for Facilitating Weapons Procurement from Russia via Crypto](https://www.chainalysis.com/blog/ofac-sanctions-houthi-network-crypto-money-laundering-russia-april-2025/) - [US Treasury Sanctions Houthi Financial Networks Including Eight Crypto Addresses | TRM Blog](https://www.trmlabs.com/resources/blog/us-treasury-sanctions-houthi-financial-networks-including-eight-crypto-addresses) - [Counter Terrorism Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250722) - [Counter Terrorism Designations and Designation Update | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20260116) - [Non-Proliferation Designations; Iran-related and Counter Terrorism Designations, Designation Updates, and Designation Removal | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250620) - [Cyber-related Designations; Counter Terrorism Designations and Designation Update; Issuance of Amended Counter Terrorism General Licenses and New Frequently Asked Question | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20250305) - [Yemen Seizes 1.5 Million Captagon Pills, Alleges Houthis Fueling War Through Drug Trade | OCCRP](https://www.occrp.org/en/news/yemen-seizes-15-million-captagon-pills-alleges-houthis-fueling-war-through-drug-trade) - [OFAC Sanctions eight Ansarallah (the Houthis) crypto addresses, Increasing pressure on the re-designated Foreign Terror Organization (FTO) and its patron, Iran](https://www.elliptic.co/blog/ofac-sanctions-eight-ansarallah-the-houthis-crypto-addresses) - [2025 Crypto Regulatory Round-Up](https://www.chainalysis.com/blog/2025-crypto-regulatory-round-up/) - [Middle East & North Africa: Regulatory Momentum and DeFi Fuel Adoption - Chainalysis](https://www.chainalysis.com/blog/middle-east-north-africa-crypto-adoption-2024/) - [Global Crypto Policy Review Outlook 2025/26 Report | TRM Labs](https://www.trmlabs.com/reports-and-whitepapers/global-crypto-policy-review-outlook-2025-26) - [FSB thematic review 2025: Global crypto regulation remains fragmented despite market growth](https://www.elliptic.co/blog/fsb-thematic-review-2025) - [How crypto regulation changed in 2025: a global review](https://www.elliptic.co/blog/how-crypto-regulation-changed-in-2025) - [Middle East & North Africa Crypto Adoption Trends and Analysis](https://www.chainalysis.com/blog/middle-east-north-africa-mena-cryptocurrency-adoption/) - [Virtual Assets](https://www.fatf-gafi.org/en/topics/virtual-assets.html) - [Global crypto regulation review 2025](https://www.elliptic.co/resources/global-crypto-regulation-review-2025) - [Crypto regulatory affairs: UAE takes steps to bolster its crypto regulatory framework](https://www.elliptic.co/blog/uae-takes-steps-to-bolster-its-crypto-regulatory-framework) - [Saudi Central Bank Hires Crypto Chief to Boost Digital Ambitions - Bloomberg](https://www.bloomberg.com/news/articles/2022-09-04/saudi-central-bank-hires-crypto-chief-to-boost-digital-ambitions) - [Saudi Arabia Arrests 21, Mainly Public Officials, for Corruption | OCCRP](https://www.occrp.org/en/news/saudi-arabia-arrests-21-mainly-public-officials-for-corruption) - [Saudi Arabia Arrests 127 in Ongoing Anti-Corruption Campaign | OCCRP](https://www.occrp.org/en/news/saudi-arabia-arrests-127-in-ongoing-anti-corruption-campaign) - [Saudi Arabia Detains 136 People in Latest Anti-Corruption Drive | OCCRP](https://www.occrp.org/en/news/saudi-arabia-detains-136-people-in-latest-anti-corruption-drive) - [Saudi Prosecutor to Investigate Corruption Cases | OCCRP](https://www.occrp.org/en/news/saudi-prosecutor-to-investigate-corruption-cases) - [Saudi Arabia Detains 298 Government Officials for Graft | OCCRP](https://www.occrp.org/en/news/saudi-arabia-detains-298-government-officials-for-graft) - [Trying to Curb Corruption, Saudi Arabia Arrests 226 Suspects | OCCRP](https://www.occrp.org/en/news/trying-to-curb-corruption-saudi-arabia-arrests-226-suspects) - [1 Information Provided by Saudi Arabia’s Oversight and Anti-Corruption](https://www.unodc.org/documents/treaties/UNCAC/WorkingGroups/workinggroup4/2022-June-13-17/Contributions/Saudi_Arabia_EN.pdf) - [Saudi Arabia Arrests Over 200 in Latest Corruption Crackdown | OCCRP](https://www.occrp.org/en/daily/14987-saudi-arabia-arrests-over-200-in-latest-corruption-crackdown) - [Country Review Report of the Kingdom of Saudi Arabia](https://www.unodc.org/documents/treaties/UNCAC/CountryVisitFinalReports/2015_10_12_Saudi_Arabia_Cycle_I_Country_Report_EN.pdf) - [Saudi Arabia’s measures to fight money laundering and the financing of terrorism and proliferation](https://www.fatf-gafi.org/en/publications/mutualevaluations/documents/mer-saudi-arabia-2018.html) - [Saudi Arabia Strengthens Anti-Corruption Legislation | OCCRP](https://www.occrp.org/en/news/saudi-arabia-strengthens-anti-corruption-legislation) - [Fatf-gafi](https://www.fatf-gafi.org/media/fatf/documents/reports/mer/MER-Saudi-Arabia-2018-Executive-Summary.pdf) - [December 2024 Anti-money laundering and counter-terrorist financing measures](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/Comms%20MER%20Oman%202024.pdf.coredownload.inline.pdf) - [Public Statement on revisions to R.24](https://www.fatf-gafi.org/en/publications/Fatfrecommendations/R24-statement-march-2022.html) - [The Anti-Money Laundering Act of 2020 | FinCEN.gov](https://www.fincen.gov/anti-money-laundering-act-2020) - [FATF Recommendations](https://www.fatf-gafi.org/en/topics/fatf-recommendations.html) - [5th Enhanced Follow-Up Report for The Kingdome of ...](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/Morocco-FUR-MENAFATF-May-2024.pdf) - [REPORT ON THE STATE OF EFFECTIVENESS AND COMPLIANCE WITH THE FATF STANDARDS](https://www.fatf-gafi.org/content/dam/fatf-gafi/reports/Report-on-the-State-of-Effectiveness-Compliance-with-FATF-Standards.pdf.coredownload.pdf) - [Fatf-gafi](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/Follow-Up-Report-Saudi-Arabia-2020.pdf.coredownload.pdf) - [The 2022 and 2013 Methodologies for Assessing Technical Compliance with the FATF Recommendations and the Effectiveness of AML/CFT/CPF Systems](https://www.fatf-gafi.org/en/publications/Mutualevaluations/Fatf-methodology.html) - [Frequently Asked Questions](https://www.fatf-gafi.org/en/pages/frequently-asked-questions.html) - [Global Magnitsky Designations | Office of Foreign Assets Control](https://ofac.treasury.gov/recent-actions/20210226) - [It’s the end of the year, the Global Magnitsky sanctions are here | Global Witness](https://globalwitness.org/en/campaigns/land-and-environmental-defenders/its-the-end-of-the-year-the-global-magnitsky-sanctions-are-here/) - [U.K. Announces Sanctions on 49 Individuals and Organizations](https://www.bloomberg.com/news/articles/2020-07-06/u-k-announces-sanctions-on-49-individuals-and-organizations) - [Saudis Vow to Hit Back Against Any Measures Over Khashoggi - Bloomberg](https://www.bloomberg.com/news/articles/2018-10-14/saudi-arabia-says-it-will-retaliate-against-punitive-measures) - [Sanctions Advocate Bill Browder Faults Joe Biden Over Jamal Khashoggi Report - Bloomberg](https://origin.www.bloomberg.com/news/articles/2021-03-09/sanctions-advocate-browder-faults-biden-over-khashoggi-report) - [Khashoggi Murder: How Graham Plans to Punish Saudis - Bloomberg](https://www.bloomberg.com/opinion/articles/2018-12-05/khashoggi-murder-how-graham-plans-to-punish-saudis) - [U.K. to Name Russians Facing Visa Bans Under New Sanction Rules - Bloomberg](https://www.bloomberg.com/news/articles/2020-07-06/u-k-to-name-russians-facing-visa-bans-under-new-sanction-rules) - [Senators Threaten Saudi Sanctions After Trump Misses Deadline - Bloomberg](https://www.bloomberg.com/news/articles/2019-03-05/senators-threaten-saudi-sanctions-after-trump-misses-deadline) - [U.K. Confronts China, Russia to Define Role Beyond Europe - Bloomberg](https://www.bloomberg.com/news/articles/2020-07-06/u-k-chooses-fights-as-it-seeks-its-place-in-a-post-brexit-world) - [UK Issues ‘Magnitsky-Style’ Sanctions, First Since Brexit | OCCRP](https://www.occrp.org/en/daily/12708-uk-issues-magnitsky-style-sanctions-first-since-brexit) - [PGA-LIV Golf Probe Hampered by Saudi Wealth Fund PIF, US Senate Says - Bloomberg](https://www.bloomberg.com/news/articles/2024-01-31/senate-panel-rebukes-saudi-fund-for-obstructing-liv-pga-inquiry) - [Watch LIV Golf Faces Uncertain Future as Saudi PIF Pulls Support - Bloomberg](https://www.bloomberg.com/news/videos/2026-05-20/liv-golf-faces-uncertain-future-as-saudi-support-pulled-video) - [Saudi Arabia Wealth Fund PIF Ordered to Give Evidence in PGA-LIV Antitrust Suit - Bloomberg](https://www.bloomberg.com/news/articles/2023-02-17/saudi-fund-ordered-to-provide-evidence-in-pga-liv-antitrust-suit) - [PGA-LIV Golf US Court Fight: Saudi Wealth Fund Claims Immunity - Bloomberg](https://www.bloomberg.com/news/articles/2022-11-23/saudi-wealth-fund-claims-immunity-in-pga-liv-golf-us-court-fight) - [LIV Golf's Future in Doubt as Saudi Arabia PIF Wants ...](https://www.bloomberg.com/news/articles/2026-04-16/saudis-now-want-sports-to-make-money-clouding-liv-golf-s-future) - [LIV Golf Taps Advisers to Find New Investors After PIF’s Exit - Bloomberg](https://www.bloomberg.com/news/articles/2026-05-05/liv-golf-taps-advisers-to-find-new-investors-after-pif-s-exit) - [PGA Seeks to Sue Saudi Investment Fund and its Chief in LIV Golf Feud - Bloomberg](https://www.bloomberg.com/news/articles/2023-01-25/pga-seeks-to-sue-saudi-investment-fund-and-its-chief-in-feud) - [US Treasury Department abandoned major money laundering case against Dubai gold company - ICIJ](https://www.icij.org/investigations/fincen-files/us-treasury-department-abandoned-major-money-laundering-case-against-dubai-gold-company/) - [Saudi Wealth Fund, PGA Hit “Impasse” Over Documents in LIV Suit](https://www.bloomberg.com/news/articles/2023-01-20/saudi-wealth-fund-pga-hit-impasse-over-documents-in-liv-suit) - [Anti-money laundering and countering the financing of terrorism at international level - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level_en) - [European Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [High risk third countries and the international context content of anti-money laundering and countering the financing of terrorism - European Commission](https://finance.ec.europa.eu/financial-crime/high-risk-third-countries-and-international-context-content-anti-money-laundering-and-countering_en) - [EU methodology for the identification of high-risk third countries - Finance](https://finance.ec.europa.eu/financial-crime/anti-money-laundering-and-countering-financing-terrorism-international-level/eu-methodology-identification-high-risk-third-countries_en) - [Commission updates list of high-risk countries to strengthen international fight against financial crime - Finance](https://finance.ec.europa.eu/news/commission-updates-list-high-risk-countries-strengthen-international-fight-against-financial-crime-2025-06-10_en) - [Protecting the EU’s financial system - Finance - European Commission](https://finance.ec.europa.eu/news/protecting-eus-financial-system-2025-07-16_en) - [Methodology for identifying high-risk third countries under ...](https://finance.ec.europa.eu/document/download/f745b6e8-735b-4855-b050-f52276356fe6_en) - [Anti-money laundering: the Commission updates its list of high-risk third-country jurisdictions to strengthen the international fight against financial crime - Finance](https://finance.ec.europa.eu/news/anti-money-laundering-commission-updates-its-list-high-risk-third-country-jurisdictions-strengthen-2022-12-20_en) - [High-risk and other monitored jurisdictions](https://www.fatf-gafi.org/en/topics/high-risk-and-other-monitored-jurisdictions.html) - [Money laundering and terrorist financing: Council returns draft list of high risk countries to the Commission - Consilium](https://www.consilium.europa.eu/en/press/press-releases/2019/03/07/money-laundering-and-terrorist-financing-council-returns-draft-list-of-high-risk-countries-to-the-commission/) - [3rd Enhanced Follow-up Report for the United Arab Emirates](https://www.fatf-gafi.org/content/dam/fatf-gafi/fsrb-fur/UAE-Follow-Up-Report-2023.pdf.coredownload.pdf) - [Countries / Jurisdictions](https://www.fatf-gafi.org/en/countries.html) - ["Black and grey" lists](https://www.fatf-gafi.org/en/countries/black-and-grey-lists.html) - [The United Arab Emirates' progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/FUR-UAE-2023.html) - [United States' progress in strengthening measures to tackle money laundering and terrorist financing](https://www.fatf-gafi.org/en/publications/Mutualevaluations/united-states-fur-2024.html) - [Saudi Arabia Arrests 21, Mainly Public Officials, for Corruption](https://www.occrp.org/en/27-ccwatch/cc-watch-briefs/15359-saudi-arabia-arrests-21-mainly-public-officials-for-corruption) - [Saudi Arabia Arrests Over 200 in Latest Corruption Crackdown | OCCRP](https://www.occrp.org/en/news/saudi-arabia-arrests-over-200-in-latest-corruption-crackdown) - [Oversight and Anti-Corruption Authority (Nazaha) | OCCRP](https://www.occrp.org/en/organizations/oversight-and-anti-corruption-authority-nazaha/page/1) - [Trying to Curb Corruption, Saudi Arabia Arrests 226 Suspects | OCCRP](https://www.occrp.org/en/daily/13469-trying-to-curb-corruption-saudi-arabia-arrests-226-suspects) - [Nazaha | OCCRP](https://www.occrp.org/en/organizations/nazaha) - [Financial Action Task Force (FATF)](https://www.fatf-gafi.org/en/countries/detail/Saudi-Arabia.html) - [FATF / MENAFATF](https://www.fatf-gafi.org/content/dam/fatf-gafi/mer/MER-Saudi-Arabia-2018.pdf) - [US Department of the Treasury (OFAC)](https://ofac.treasury.gov/recent-actions/20250722) - [US Department of the Treasury (OFAC)](https://ofac.treasury.gov/recent-actions/20260116) - [US Department of the Treasury (OFAC)](https://ofac.treasury.gov/recent-actions/20250328) - [Chainalysis](https://www.chainalysis.com/blog/ofac-sanctions-houthi-network-crypto-money-laundering-russia-april-2025/) - [TRM Labs](https://www.trmlabs.com/resources/blog/us-treasury-sanctions-houthi-financial-networks-including-eight-crypto-addresses) - [Elliptic (reporting on FSB)](https://www.elliptic.co/blog/fsb-thematic-review-2025) - [OCCRP](https://www.occrp.org/en/news/yemen-seizes-15-million-captagon-pills-alleges-houthis-fueling-war-through-drug-trade) - [European Commission](https://finance.ec.europa.eu/news/european-commission-updates-list-high-risk-countries-strengthen-international-fight-against-2025-12-04_en) - [Chainalysis](https://www.chainalysis.com/blog/middle-east-north-africa-crypto-adoption-2024/) - [OCCRP](https://www.occrp.org/en/news/saudi-arabia-arrests-127-in-ongoing-anti-corruption-campaign) Coverage gaps fim-int-2026-07-05-G001: No post-2018 effectiveness re-asses… fim-int-2026-07-05-G001: No post-2018 effectiveness re-assessment exists for Saudi Arabia's AML/CFT confiscation and terrorist-financing-disruption performance; a fresh FATF/MENAFATF effectiveness-focused evaluation would close this gap. [resolved] fim-int-2026-07-05-G002: SAMA/CMA do not publish an English-… fim-int-2026-07-05-G002: SAMA/CMA do not publish an English-language granular AML/CFT enforcement-penalty register; disclosure of individual supervisory actions would allow independent verification of domestic enforcement intensity. [resolved] fim-int-2026-07-05-G003: No confirmed FATF R.24-depth benefi… fim-int-2026-07-05-G003: No confirmed FATF R.24-depth beneficial-ownership register data for Saudi Arabia's Ministry of Commerce registry; direct documentation of BO-field completeness would resolve this. [resolved] fim-int-2026-07-05-G004: The precise legal scope of Saudi Ar… fim-int-2026-07-05-G004: The precise legal scope of Saudi Arabia's crypto-activity restriction (bank/financial-institution-facing versus individual-ownership prohibition) is disputed between the FSB's classification and independent legal analysis; a primary-source SAMA/CMA regulatory-text citation would resolve the discrepancy. [resolved] fim-int-2026-07-05-G005: FATF's assessments calendar lists a… fim-int-2026-07-05-G005: FATF's assessments calendar lists a November 2026 possible onsite period for Saudi Arabia as indicative only; confirmation of the finalized mutual-evaluation timeline would improve horizon-dating confidence. [resolved] fim-int-2026-07-05-G006: No 2025-2026-window corroborating s… fim-int-2026-07-05-G006: No 2025-2026-window corroborating source was identified for the PIF sovereign-immunity/discovery-obstruction pattern beyond the January 2024 Senate rebuke; a current-window primary or press source directly addressing PIF disclosure practices would confirm whether the scheme remains actively evolving. [resolved] fim-int-2026-08-05-G001: No Tier-1 SAMA/CMA primary source r… fim-int-2026-08-05-G001: No Tier-1 SAMA/CMA primary source retrieved for the reported Digital Assets Regulatory Framework capital thresholds, stablecoin policy, or CMA AML wallet-verification guidance. [resolved] fim-int-2026-08-05-G002: No Tier-1/2 primary regulation text… fim-int-2026-08-05-G002: No Tier-1/2 primary regulation text located for the lowered traveller cash/valuables declaration threshold. [resolved] fim-int-2026-08-05-G003: No Tier-1 Ministry of Commerce prim… fim-int-2026-08-05-G003: No Tier-1 Ministry of Commerce primary decision text located confirming the exact Decision 267/235 succession wording. [resolved] fim-int-2026-08-05-G004: Single-source (Tier-3) corroboratio… fim-int-2026-08-05-G004: Single-source (Tier-3) corroboration only for the precious-metals/gemstone DNFBP Taqasiy registration mandate. [resolved] fim-int-2026-08-05-G005: Tier D watch jurisdictions (Cambodi… fim-int-2026-08-05-G005: Tier D watch jurisdictions (Cambodia, Laos, Mexico, Colombia) were not searched this cycle as the dispatch was bound to Saudi Arabia. [resolved] fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G001 ({'scheme': 'financial_integrity', 'value': 'D2'}): No T1 Ministry of Commerce or Umm Al-Qura gazette page was reached this cycle to corroborate the MoC UBO Rules replacement (Ministerial Decision No. 267) at primary-source level. [resolved] fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G002 ({'scheme': 'financial_integrity', 'value': 'D5'}): The CMA Digital Asset Market Guidance and associated SAR 2.5 million fine rest on a single Tier-4 vendor-blog source with no reachable CMA primary confirmation this cycle. [resolved] fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-05-G003 ({'scheme': 'financial_integrity', 'value': 'D3'}): D3, D4 and D6 returned thin coverage this cycle with no SA-specific material surfaced beyond structural context already captured elsewhere. [resolved] fim-int-2026-09-05-G004: Tier D jurisdiction watch (KH/LA/MX… fim-int-2026-09-05-G004: Tier D jurisdiction watch (KH/LA/MX/CO) was not independently re-searched this cycle owing to pooled union web-search budget allocation. [resolved] fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G001 ({'scheme': 'financial_integrity', 'value': 'D5'}): No primary CMA text has been retrieved to corroborate the reported 'Digital Asset Market Guidance' or the March 2026 wallet-verification enforcement fine; both rest on a single T3 source. [resolved] fim-int-2026-09-28-G002: D3 (Enabler Jurisdictions), D4 (Con… fim-int-2026-09-28-G002: D3 (Enabler Jurisdictions), D4 (Conflict Finance), and D6 (Compliance Technology) had no SA-specific findings this cycle; coverage was thin across searched sources. [resolved] fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', '… fim-int-2026-09-28-G003 ({'scheme': 'financial_integrity', 'value': 'D2'}): No primary Ministerial Decision No. 267 text or Companies Law implementing regulations text was retrieved this cycle; both rest on T3 law-firm secondary commentary. [resolved] fim-int-2026-10-11-G001: Specific SAR fine amounts attribute… fim-int-2026-10-11-G001: Specific SAR fine amounts attributed to named institutions reported by SEO-style compliance-vendor sites could not be corroborated against a primary SAMA enforcement notice this cycle and were withheld from enforcement_actions. [resolved] fim-int-2026-10-11-G002: Tier-D jurisdictions (KH/LA/MX/CO) … fim-int-2026-10-11-G002: Tier-D jurisdictions (KH/LA/MX/CO) were not actively searched this cycle given the pooled union research budget; recorded as awaiting_primary_source rather than no_source. [resolved] fim-int-2026-10-18-G001: UN Panel of Experts (Yemen) and OFA… fim-int-2026-10-18-G001: UN Panel of Experts (Yemen) and OFAC/OFSI Yemen-Houthi channels were not separately queried this cycle for SA-relevant content. [resolved] fim-int-2026-10-18-G002: The specific OFAC Federal Register … fim-int-2026-10-18-G002: The specific OFAC Federal Register notice naming the Saudi Arabia-domiciled entity in Operation Economic Outcast was not independently retrieved this cycle. [resolved] fim-int-2026-10-18-G003: Laos, Mexico and Colombia were not … fim-int-2026-10-18-G003: Laos, Mexico and Colombia were not separately queried this cycle due to pooled-budget prioritisation of the bound JID. [resolved] fim-int-2026-10-25-G001: Tier D jurisdictions (Cambodia, Lao… fim-int-2026-10-25-G001: Tier D jurisdictions (Cambodia, Laos, Mexico, Colombia) were not actively re-searched this cycle due to pooled web-search budget allocation to Saudi Arabia. [open] fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', '… fim-int-2026-10-25-G002 ({'scheme': 'financial_integrity', 'value': 'D7'}): No AML Law implementing regulations text has been located confirming the operative detail of the April 2026 amendments beyond the decree register and secondary commentary. [open] fim-int-2026-11-04-G001 ({'scheme': 'financial_integrity', '… fim-int-2026-11-04-G001 ({'scheme': 'financial_integrity', 'value': 'D1'}): No primary CST (Communications, Space and Technology Commission) or SAMA enforcement bulletin for SA within the window was located; all D1, D3, D4, D5, D6 remain thin-coverage this cycle. [open] FIM-GAP-001 (D1): FATF's enhanced follow-up process for Saud… FIM-GAP-001 (D1): FATF's enhanced follow-up process for Saudi Arabia re-rates only technical compliance, not effectiveness; the 2018 MER's effectiveness findings (weak proceeds-of-crime confiscation, limited use of targeted financial sanctions to disrupt terrorist financing beyond the Kingdom) have not been re-tested in a subsequent full evaluation. FIM-GAP-002 (D5): Saudi Arabia maintains an outright prohibi… FIM-GAP-002 (D5): Saudi Arabia maintains an outright prohibition on cryptoasset activities (grouped with China by the FSB's 2025 thematic review) rather than a licensed, supervised VASP regime, even as retail and institutional crypto adoption has grown rapidly, leaving transactions to occur through unregulated OTC brokers and offshore VASPs outside SAMA/CMA AML/CFT visibility. FIM-GAP-003 (D3): Unlike FinCEN/OFAC or OFSI, SAMA and the C… FIM-GAP-003 (D3): Unlike FinCEN/OFAC or OFSI, SAMA and the CMA do not appear to publish a comparably granular, English-language public register of individual AML/CFT supervisory penalties or enforcement actions against regulated entities, limiting external verification of domestic bank/DPMS-sector enforcement intensity. FIM-GAP-004 (D2): No centralized, FATF-Recommendation-24-com… FIM-GAP-004 (D2): No centralized, FATF-Recommendation-24-compliant public beneficial-ownership register for legal persons comparable to the UK PSC register or EU BORIS interconnection was identified for Saudi Arabia; commercial registration data is held via the Ministry of Commerce registry referenced in UNODC's open-source registry directory, but its beneficial-ownership depth and public accessibility could not be confirmed from available sources at baseline. ## Evidence #### Confidence-tiered claims Security Council Resolutions Notification System for payment systems and operators [[Source 1]](#sec-sources) Probable · 1 source Wathq, Private Associations and Foundations inquiry service, and General Authority for Awqaf verification service [[Source 1]](#sec-sources) Probable · 1 source Not on FATF's current black or grey list; last mutual evaluation adopted Sep 2018 (not 2022 as a T4 vendor claimed), possible onsite Nov 2026. [[Source 1]](#sec-sources) Disputed · 1 source mBridge, the China-led cross-border multi-CBDC settlement platform [[Source 1]](#sec-sources) Probable · 1 source barq $329.5m Series A, Tabby $233m Series F, Tarabut financing, Fina SAR 500m CMA-licensed fund, erad $22m Series A, within trailing 12 months [[Source 1]](#sec-sources) Probable · 1 source Iranian MODAFL procurement network including an entity located in Saudi Arabia, under EO 13382/13902 [[Source 1]](#sec-sources) Probable · 1 source mBridge cross-border CBDC platform; participation was a limited proof-of-concept trial ending 13 May 2025 with no further phases [[Source 1]](#sec-sources) Probable · 1 source Compliant on 17 of 40 Recommendations, largely compliant on 21; R.18 and R.21 downgraded since 2018; not on FATF grey/black list [[Source 1]](#sec-sources) Probable · 1 source Nationwide audit of 195 licensed casinos in August 2026 (20 revocations, 29 suspensions, 23 lapses) and sector-wide suspension of online/live-dealer betting from October 2026, framed as preventing money-laundering use. [[Source 1]](#sec-sources) Probable · 1 source Possible onsite assessment for SA's 5th-round FATF/MENAFATF mutual evaluation opens 2026-11-01, with possible plenary discussion around mid-2027. [[Source 1]](#sec-sources) Probable · 1 source Saudi Arabia is not on the FATF black or grey list or the EU high-risk third-country list. [[Source 1]](#sec-sources) Probable · 1 source Saudi Arabia not on FATF black or grey list; remains in enhanced follow-up since 2018 mutual evaluation; 5th-round onsite assessment scheduled around November 2026 [[Source 1]](#sec-sources) Probable · 1 source Draft legislation approved 11 October 2026 designating the Houthis a terrorist organisation, following an attack on Riyadh airport [[Source 1]](#sec-sources) Probable · 1 source Restrictive sandbox-only posture on public crypto trading; undelivered SAMA+CMA stablecoin policy initiative first signalled late 2025 [[Source 1]](#sec-sources) Uncertain · 1 source AML Law (Royal Decree M/20, 1439H) as amended by Royal Decree D/223 (15 April 2026); SAMA Circular 472035766 and CMA Resolution 4-163-2025 (Dec 2025) Targeted Financial Sanctions implementation rules, both in force [[Source 1]](#sec-sources) Probable · 1 source New UBO rules (Ministerial Decision 267, 26 November 2025) effective 4 January 2026, applying a three-tier UBO test (25% ownership, effective control, or manager/board member/chairman) to most company forms [[Source 1]](#sec-sources) Probable · 1 source