1. Home
  2. |Insights
  3. |Saudi Shoura Council Approves Draft Amended Anti-Money Laundering Law

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 | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....