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Draft Investment Accounts Instructions Issued by Saudi Arabian Capital Market Authority for Public Consultation

Client Alert | 1 min read | 01.15.16

As part of the efforts of the Saudi Arabian Capital Market Authority (the CMA) to develop the Saudi Arabian capital market and protect investors, and pursuant to the Capital Market Regulations as enacted by Royal Decree Number M/30 dated 2/6/1424 H / 1 August 2003, the Board of the CMA has published draft Investment Accounts Instructions (the Draft Instructions) on the CMA's website to allow concerned and interested parties to provide their comments and observations.

The Draft Instructions aim to regulate the opening and operation of investment accounts held by authorized persons licensed to undertake dealing, managing, or custody activities and to define the related investment account controls and supervisory rules.

The CMA will accept comments and observations on the Draft Instructions via email to Rules.Regulations@cma.org.sa no later than Monday 29/4/1437 H / 8 February 2016. The CMA notes that it will study and consider all comments and observations prior to issuing final Instructions.

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Client Alert | 5 min read | 12.12.25

Eleventh Circuit Hears Argument on False Claims Act Qui Tam Constitutionality

On the morning of December 12, 2025, the Eleventh Circuit heard argument in United States ex rel. Zafirov v. Florida Medical Associates, LLC, et al., No. 24-13581 (11th Cir. 2025). This case concerns the constitutionality of the False Claims Act (FCA) qui tam provisions and a groundbreaking September 2024 opinion in which the United States District Court for the Middle District of Florida held that the FCA’s qui tam provisions were unconstitutional under Article II. See United States ex rel. Zafirov v. Fla. Med. Assocs., LLC, 751 F. Supp. 3d 1293 (M.D. Fla. 2024). That decision, penned by District Judge Kathryn Kimball Mizelle, was the first success story for a legal theory that has been gaining steam ever since Justices Thomas, Barrett, and Kavanaugh indicated they would be willing to consider arguments about the constitutionality of the qui tam provisions in U.S. ex rel. Polansky v. Exec. Health Res., 599 U.S. 419 (2023). In her opinion, Judge Mizelle held (1) qui tam relators are officers of the U.S. who must be appointed under the Appointments Clause; and (2) historical practice treating qui tam and similar relators as less than “officers” for constitutional purposes was not enough to save the qui tam provisions from the fundamental Article II infirmity the court identified. That ruling was appealed and, after full briefing, including by the government and a bevy of amici, the litigants stepped up to the plate this morning for oral argument....