Saudi Shoura Council Approves Draft Amended Anti-Money Laundering Law
Client Alert | 1 min read | 03.01.12
In response to recommendations made in a 2010 Middle East and North Africa Financial Action Task Force Report on Saudi Arabia's anti-money laundering (AML) and counter-terrorist financing (CFT) regime (the Report), Saudi Arabia's Shoura Council approved on 27 February 2012 a draft amended anti-money laundering law (the Draft Law).
Saudi Arabia's existing AML / CFT regime was established in 2003 with the issuance of the Anti Money Laundering Act (AMLA) and supplemented by implementing regulations issued in 2007. The Report identified a number of areas for improvement in Saudi Arabia's existing AML / CFT regime, including:
- The AMLA does not clearly cover self-laundering and does not clearly extend to predicate offences committed abroad.
- There is no stand-alone statutory terrorist financing (TF) offence with features and elements as required by the United Nations' Terrorist Financing Convention (the UN TF Convention).
- TF as a money laundering offence does not extend to all legal entities or to all funds as required by the UN TF Convention.
- TF as a money laundering offence does not cover acts by terrorist organizations of fewer than three persons, nor does it cover attempted TF.
- While the AMLA contains specific provisions for confiscation in AML / CFT proceedings, protection of bona fide third parties is insufficient.
The Draft Law, which has not been released to the public, will reportedly seek to address some of the more urgent concerns raised by the Report.
Insights
Client Alert | 1 min read | 04.18.24
GSA Clarifies Permissibility of Upfront Payments for Software-as-a-Service Offerings
On March 15, 2024, the General Services Administration (GSA) issued Acquisition Letter MV-2024-01 providing guidance to GSA contracting officers on the use of upfront payments for acquisitions of cloud-based Software-as-a-Service (SaaS). Specifically, this acquisition letter clarifies that despite statutory prohibitions against the use of “advance” payments outside of narrowly-prescribed circumstances, upfront payments for SaaS licenses do not constitute an “advance” payment subject to these restrictions when made under the following conditions:
Client Alert | 4 min read | 04.18.24
Client Alert | 6 min read | 04.16.24
Navigating the AI Intellectual Property Maze - Key Points From Congressional Hearing
Client Alert | 5 min read | 04.15.24
Making the EU Courts More Efficient for Trade-Related Decisions
