SAUDI ARABIA Trends and Developments Contributed by: Saud AlRomi, Mostafa Ihab and Saleh Elbadry, Mohammed AlDhabaan & Partners Eversheds Sutherland
International Integration: FATF Membership and Cross-Border Recovery The Financial Action Task Force (FATF) is an intergov - ernmental body of 40 members that sets international standards for combating money laundering, terrorist financing and related threats to the integrity of the financial system. Member countries are subject to periodic peer review, with results published publicly. In June 2019, Saudi Arabia joined FATF as the first Arab country and the 37th member globally. As of 2024, Saudi Arabia is fully compliant with 17 of FATF’s 40 Recommendations and largely compliant with 21 oth - ers, with only two areas rated partially compliant. The cross-border asset recovery framework is set out in Articles 38 to 42 of the Anti-Money Laundering Law. Under Article 38, Saudi competent authorities may exchange information with foreign counterparts on a treaty or reciprocity basis. Under Article 39, Sau - di authorities may provide mutual legal assistance in tracing, seizing, and confiscating fraud proceeds upon request from a foreign court or authority in a treaty or reciprocity country. Article 40 provides for recognition and enforcement of foreign confiscation orders, subject to the condition that the assets can be confiscated under Saudi law. Article 41 permits the extradition of money laundering suspects on a treaty or reciprocity basis; where extradition is refused, Sau - di courts may try the matter themselves using inves - tigations provided by the requesting country. Article 42 designates the Permanent Committee for Mutual Legal Assistance as the body responsible for receiving and handling all international requests.
FATF membership means that Saudi Arabia’s co-oper - ation commitments are assessed and rated publicly by an independent peer body. For a foreign fraud vic - tim tracing proceeds to Saudi Arabia, that member - ship provides a more reliable basis for co-operation than a purely bilateral or ad hoc arrangement. Conclusion Saudi Arabia’s fraud and asset tracing landscape has changed across four distinct dimensions in recent years. Enforcement is active at volume – Nazaha’s 2025 statistics, the revised Nazaha Law’s strength - ened asset recovery powers and the CMA’s multi-year referral record all demonstrate a system in operation. The digital enforcement infrastructure has shortened the time from court order to asset freeze, connected enforcement courts directly to banks and payment providers, and made 98% of judicial proceedings remote. The Companies Law 2022 provides a statu - tory framework for criminal prosecution and civil com - pensation against corporate insiders, with the public prosecution designated as the authority for investi - gation and prosecution. The Whistleblower Law has addressed the detection gap by pairing legal protec - tion for those who report with a financial incentive to do so. And Saudi Arabia’s FATF membership and cross-border recovery framework, with full or largely compliant ratings across 38 of 40 Recommendations as of 2024, provide the international infrastructure needed when fraud proceeds leave the Kingdom.
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