International Fraud and Asset Tracing 2026

SAUDI ARABIA Trends and Developments Contributed by: Saud AlRomi, Mostafa Ihab and Saleh Elbadry, Mohammed AlDhabaan & Partners Eversheds Sutherland

financial disclosure. Nazaha’s enforcement activity therefore directly feeds the fraud and asset recovery process. In capital markets, the CMA has established a pat - tern of referring fraud cases to the public prosecution. In early 2024, the CMA referred a group of investors to the public prosecution for allegedly rigging stock prices across 52 listed companies on Tadawul. In May 2025, the CMA referred further suspects for manipu - lating a share offering and engaging in fraudulent trad - ing. In 2023, the CMA secured SAR4.2 million in fines against two firms for unlicensed trading and advertis - ing securities on social media, describing the outcome as the result of co-ordination between the CMA, the public prosecution and the relevant security authori - ties. Referral to the public prosecution activates the Anti-Money Laundering Law’s investigative and sei - zure powers – including ex parte provisional asset freezing orders – in addition to the regulatory track. Convicted violators are publicly named, and victims retain access to civil compensation through the CMA’s dispute resolution committee. The Digital Transformation of Enforcement Infrastructure The Ministry of Justice has digitised its enforcement and judicial services in a way that has directly changed the practical speed of asset recovery. The primary platform is Najiz.sa, through which all judicial services – including enforcement – are now accessed. In the first half of 2024, Najiz delivered more than 43 million services without requiring physical vis - its to judicial facilities. In Q1 2024 alone, the platform recorded 23 million visits from more than 90 countries. The platform provides more than 160 judicial services through four portals serving individuals, businesses, lawyers and government agencies. By 2023, the auto - mation rate for judicial services had reached 86.94%, surpassing the Ministry’s own targets by 8.4%, and client satisfaction with judicial services reached 97%. In the 2024 Government Electronic and Mobile Ser - vices Maturity Index, Saudi Arabia was named the leading country in e-government services across the Middle East and North Africa for the third consecutive year, and ranks second among G20 nations for the quality and reach of its online services.

In 2024, 98% of more than 2.3 million court sessions were conducted remotely via the electronic litigation service. The average number of sessions required to close a case reached two – 33% more efficient than 2023. Nafith is the Ministry of Justice’s platform for promis - sory notes, launched in April 2020. It allows individu - als, banks and financial institutions to issue, register and manage promissory notes electronically, with direct linkage to the enforcement courts. The Saudi Central Bank (Saudi Arabian Monetary Authority – SAMA) has informed all banks that they can connect directly to Nafith and integrate it with their own sys - tems. When a promissory note is properly registered on Nafith, the enforcement authority can order asset freezes, salary deductions or travel bans without additional evidentiary hearings. For Nafith-registered promissory notes, the Ministry of Justice has reduced enforcement to two automatic procedural steps. A Virtual Enforcement Court, accessible through Najiz, operates around the clock with automatic review of applications, referral to the judicial panel and com - pletion of enforcement – with no requirement for in- person appearances. The integration between the enforcement system and the financial sector is equally important for fraud recovery. SAMA has issued binding instructions requiring payment service companies to immediately suspend a customer’s electronic wallet upon receiv - ing a ban order from an enforcement court, and to prevent any new relationships with that customer. The digital linking between the Committees for Banking and Financial Disputes and the public prosecution was completed in May 2021, enabling full electronic exchange of data between the two bodies. Electronic retail payments reached 70% of all retail transactions in 2023, up from 62% in 2022, covering 10.8 billion transactions through national payment systems. As the volume of digital financial activity increases, the speed of this court-to-financial-institution enforce - ment chain becomes increasingly important. Corporate Fraud: The Companies Law 2022 The Companies Law 1433-2022 (the “Companies Law”), which was enacted on 30 June 2022, came into force on 18 January 2023 and sets out a detailed

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