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
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On November 12, 2025, Judge King in the U.S. District Court for the Western District of Washington granted in part Haldiram India Ltd.’s (“Plaintiff” or “Haldiram”) motion for a preliminary injunction against Punjab Trading, Inc. (“Defendant” or “Punjab Trading”), a seller alleged to be importing and distributing gray market snack food products not authorized for sale in the United States. The court found that Haldiram was likely to succeed on the merits of its trademark infringement claim because the products at issue, which were intended for sale in India, were materially different from the versions intended for sale in the U.S., and for this reason were not genuine products when sold in the U.S. Although the court narrowed certain overbroad provisions in the requested order, it ultimately enjoined Punjab Trading from importing, selling, or assisting others in selling the non-genuine Haldiram products in the U.S. market.
Client Alert | 21 min read | 12.04.25
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