The recent changes on the AML law: what you need to know

On 17 April 2026, the Kingdom of Saudi Arabia’s (“KSA”) Council of Ministers approved a number of amendments to the Anti‑Money Laundering Law issued by Royal Decree No. (M/20) dated 2/2/1439H (the “AML Law”). The amendments introduce certain changes affecting regulated entities, non‑profit organisations and individuals convicted under the AML Law.

Key Amendments

• Express reference to non‑profit organisations has been removed from Articles 14, 15, 16 and 18 of the AML Law which, together, set out the core obligations under the AML Law, including the obligation of persons to which the AML Law applies (including financial institutions and designated non-financial businesses and professions) (together the “Regulated Entities”) to adopt AML policies and procedures, reporting of suspicious transactions, complying with the prohibition on tipping off and responding to Saudi Financial Intelligence Unit (“SAFIU”) requests. While this narrows their direct statutory inclusion under the AML Law, it does not necessarily remove other AML related obligations of non-profit organisations that arise under sector specific laws, licensing requirements, regulatory requirements and also laws and regulations pertaining to charities and fundraising. 
• Article 28 (paragraph 1) has been amended to clarify the position of non‑Saudi individuals convicted of money laundering offences. Under the revised provision, a convicted non‑Saudi who has been deported may re‑enter the KSA solely for the purposes of pilgrimage (Hajj or Umrah) and only in accordance with the applicable regulations.
• A new Article 33(2) has been added which provides that, without prejudice to the rights of bona fide third parties, any additional funds of a perpetrator of a money laundering offence that are disproportionate to his lawful income may be confiscated pursuant to a court judgment upon a request by the Public Prosecution, where it is established that such funds are derived from criminal conduct, unless a lawful source is proven.
• A new Article 49 has been introduced, expressly assigning the Permanent Committee for Combating Money Laundering responsibility for developing, coordinating, and periodically reviewing national risk‑based policies for combating money laundering. This includes the assessment of money laundering risks, notably risks associated with high‑risk countries. The Governor of the Saudi Central Bank is authorised to issue the internal regulations governing the Permanent Committee for Combating Money Laundering.
• In addition, Article 50 has been amended to provide that the Implementing Regulations of the AML Law, and any amendments thereto, are to be issued by the President of State Security, in agreement with the Minister of Finance, the Public Prosecutor and the Governor of the Saudi Central Bank.

Practical Considerations for Businesses and Individuals

Regulated entities should ensure that their AML policies, procedures, and training materials reflect the updated scope and structure of the AML Law. Financial institutions and Designated Non-Financial Businesses and Professions (“DNFBPs”) should not view the removal of references to non‑profit organisations as a relaxation of their own compliance obligations.

Non‑profit organisations should conduct a separate assessment to determine what their anti-money laundering obligations may apply to them under any sector specific laws, implementing regulations, licensing conditions and regulatory requirements that apply to their activities. 

The Presidency of State Security, through SAFIU, has continued to strengthen the Saudi AML reporting framework. This includes the launch of the TAQASIY electronic platform for the receipt, monitoring, analysis, and referral of suspicious transaction reports, as well as the publication of sector‑specific guidance for DNFBPs.

Businesses should also continue to reinforce source‑of‑funds, source‑of‑wealth, and beneficial ownership verification, particularly in high‑value transactions, real estate dealings, acquisitions, financing arrangements, and transactions involving high‑risk jurisdictions. Records should clearly evidence lawful source, commercial rationale, fair value and good faith.

Individuals should be aware that unexplained assets disproportionate to lawful income may now be exposed to confiscation where linked to criminal conduct. Non‑Saudi individuals should also consider the immigration consequences of an AML conviction, including deportation and restricted re‑entry rights.

Looking Ahead

Regulated entities and other stakeholders should monitor further guidance issued by the Permanent Committee for Combating Money Laundering, as well as any amendments to the Implementing Regulations of the AML Law, as the KSA continues to develop its risk‑based AML framework. Please contact any of the authors to discuss any questions you may have in relation to the matters discussed in this article.