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 | 3 min read | 05.16.25
On May 14, 2025, the Environmental Protection Agency (“EPA”) announced that it will keep the current National Primary Drinking Water Regulations (“NPDWR”) for perfluorooctanoic acid (“PFOA”) and perfluorooctane sulfonic acid (“PFOS”) under the Safe Drinking Water Act (“SDWA”), while extending the compliance deadline from 2029 to 2031. EPA further announced it plans to rescind requirements in those regulations applicable to other PFAS and mixtures of certain PFAS in drinking water. The NPDWR consists of legally enforceable primary standards and treatment techniques that apply to public water systems and guide EPA’s enforcement of the SDWA. This announcement follows EPA’s April 28, 2025 press release outlining its priorities for PFAS enforcement, which included 21 actions EPA intends to take to address PFAS and “engage with Congress and industry to establish a clear liability framework that ensures the polluter pays and passive receivers are protected.”
Client Alert | 2 min read | 05.16.25
Client Alert | 3 min read | 05.16.25
New SF-328 Released and Embedded Guidance Seeks More Information Up Front
Client Alert | 6 min read | 05.16.25
Recent Antitrust Enforcer Statements Signal New Administration’s Direction and Priorities
