Your MLRO and compliance function

What SAMA requires

SAMA's Requirements for Appointments to Senior Positions list the Chief Compliance Officer and the Director of AML/CTF among the roles that must be held by Saudi nationals. Payment and fintech companies need SAMA's written non-objection before appointing either.

Outsourcing material functions also needs SAMA's non-objection, and responsibility always stays with the licensee. Compliance work can be supported from outside; the accountable officer can't be.

CMA firms are different: the MLRO must be a CMA-registered person, and some functions can be outsourced. We confirm the position for your licence.

What we do

1. Define the roles

   Job descriptions, reporting lines and independence that SAMA or the CMA will accept.

2. Recruit

   Shortlist Saudi candidates with the right regulatory experience, and assess them for you.

3. Prepare the non-objection

   Fit-and-proper documentation and interview preparation for SAMA's review.

4. Build the programme

   Enterprise-wide risk assessment, AML/CFT policy, KYC/CDD, sanctions screening, transaction monitoring and STR procedures.

5. Co-source

   Interim and ongoing support under your appointed officers. See ongoing compliance.

Your AML/CFT programme, built to the 2026 rules

• Written to the AML Law as amended in April 2026 and the amended Implementing Regulation
• Beneficial-ownership and group-wide controls the amendments require
• Suspicious transaction reporting to SAFIU, filed without delay
• Targeted financial sanctions screening
• Board-approved, in Arabic and English