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Saudi Arabia to Open Stock Market to Foreign Financial Institutions – QFIs Rules Issued

Client Alert | 1 min read | 05.06.15

On July 22, 2014, the Saudi Arabian Capital Market Authority (CMA) announced that qualified foreign financial institutions (QFIs) would be permitted to buy and sell stocks listed on the Saudi stock market in accordance with rules to be adopted by the CMA. The CMA subsequently released its Draft Rules for Qualified Foreign Financial Institutions' Investment in Listed Shares (the Draft Rules) and solicited opinions and suggestions from investors and other interested parties on the Draft Rules.

On April 16, 2015, the CMA announced that it had adopted the following timeline to permit foreign financial institutions to buy and sell stocks listed on the Saudi stock market:

  1. Final Rules will be approved and published on 15/7/1436H (corresponding to May 4, 2015G);
  2. The Final Rules will be effective starting from 14/8/1436H (corresponding to June 1, 2015G); and
  3. QFIs shall be allowed to invest in listed shares starting from 28/8/1436H (corresponding to June 15, 2015G).

On May 4, 2015, the CMA issued its resolution Number 1-42-2015:

  1. Adopting the Rules for Qualified Foreign Financial Institutions Investment in Listed Shares (the QFIs Rules); and
  2. Adopting the following forms:
(a) Qualified Foreign Investor Application for Registration Form.

(b) Qualified Foreign Investor Client Application for Approval Form.

(c) The Minimum Requirements that must be included in the QFI Assessment Agreement Form as per Article 12 of the QFIs Rules.

(d) The Assessing Authorized Person's Acceptance Determination Template (to Register a QFI or to Approve a QFI Client).

(e) The Assessing Authorized Person's Rejection Determination Template (to Register QFI or to Approve QFI Client).

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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....

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