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Saudi Arabia's FATF mutual evaluation: what fintechs should prepare

FATF mutual evaluation of Saudi Arabia: onsite provisionally November 2026, plenary June 2027. What the 2018 report found and what fintechs need ready.

Saudi Compliance editorial teamPublished: Updated: 9 min read

The FATF Global Assessment Calendar lists Saudi Arabia's next mutual evaluation as a joint FATF and MENAFATF assessment, with a possible onsite visit in November 2026 and a possible plenary discussion in June 2027. It is a fifth-round evaluation under the FATF's 2022 Methodology, which rates effectiveness separately from technical compliance and, the FATF says, puts greater emphasis on a country's major risks and context.

For a fintech, the practical question is what evidence you can produce. Saudi supervisors will need to show assessors how licensed firms understand their risks, monitor customers, report suspicion and apply sanctions, and much of that evidence sits in firms' own files: risk assessments, suspicious transaction report (STR) decisions, screening logs and board minutes.

The FATF calendar lists a possible Saudi onsite in November 2026

The FATF publishes a Global Assessment Calendar of planned evaluations. Its rows for Saudi Arabia, Bahrain and the UAE read as follows.

CountryAssessment bodyLast evaluationPossible onsitePossible plenary discussion
Saudi ArabiaFATF and MENAFATFSeptember 2018November 2026June 2027
BahrainFATF and MENAFATFSeptember 2018November 2026June 2027
United Arab EmiratesFATF and MENAFATFApril 2020June 2026February 2027

The FATF describes these dates as possible, so treat them as a planning window. A group licensed in both Saudi Arabia and Bahrain should expect supervisory requests in both countries on the same timetable.

The plenary is where FATF members discuss and adopt the report, and the public report follows. Saudi Arabia's last report was adopted at the June 2018 plenary and published on 24 September 2018.

On the Saudi side, the Anti-Money Laundering Permanent Committee (AMLPC) has a mutual evaluation section on its website, and its secretariat has run awareness workshops for the private and public sectors, including on compliance with international standards (May and September 2025).

The 2018 report is the baseline assessors will start from

The 2018 evaluation was carried out jointly by the FATF and MENAFATF. Its headline was that Saudi Arabia was getting good results against terrorist financing but needed to focus more on pursuing larger-scale money launderers and confiscating their assets.

Several findings bear directly on regulated firms:

  • Financial institutions generally understood their money laundering and terrorist financing risks and applied customer due diligence, record-keeping and beneficial-ownership checks. The FATF attributed this largely to effective and proactive supervision.
  • The low number of suspicious transaction reports was a concern, particularly on suspected terrorist financing.
  • Money exchangers, real estate agents, accountants and other designated non-financial businesses did not fully understand their risks, with correspondingly few STRs.
  • The financial intelligence unit could not yet carry out sophisticated financial analysis.
  • Measures to implement targeted financial sanctions for proliferation financing, and to prevent sanctions evasion, were weak.

On effectiveness, the 2018 report rated Saudi Arabia on 11 immediate outcomes: four at a substantial level, four moderate and three low. On technical compliance with the 40 Recommendations, these ratings matter most to fintechs:

Recommendation2018 ratingJanuary 2020 follow-up
R.6 Targeted financial sanctions (terrorism)Partially compliantRe-rated largely compliant
R.7 Targeted financial sanctions (proliferation)Partially compliantRe-rated largely compliant
R.10 Customer due diligenceCompliantNo change reported
R.15 New technologiesLargely compliantNo change reported; see the note below
R.16 Wire transfersLargely compliantNo change reported
R.18 Internal controls and foreign branchesCompliantDowngraded to largely compliant when reassessed against the revised Recommendation
R.20 Reporting of suspicious transactionsCompliantNo change reported
R.24 Beneficial ownership of legal personsLargely compliantNo change reported

The 2018 rating for R.15 predates the FATF's virtual-asset amendments to that Recommendation. In the FATF's July 2026 update on virtual assets, Saudi Arabia's R.15 rating is shown as not applicable, meaning it has not yet been assessed against the revised standard.

The 2020 follow-up also downgraded R.21 (tipping-off and confidentiality) from compliant to largely compliant for the same reason as R.18. After that report, Saudi Arabia was compliant on 17 of the 40 Recommendations, largely compliant on 21 and partially compliant on 2. Saudi Arabia has been a FATF member since 2019.

The fifth round rates effectiveness on 11 immediate outcomes

The FATF began its fifth round in 2024 under the 2022 Methodology, which was last amended in June 2026. The Methodology has two parts. Technical compliance checks whether the laws, regulations and other instruments required by the 40 Recommendations are in place. Effectiveness checks whether they work, across 11 immediate outcomes, with greater emphasis on a country's major risks and context.

Firms are not rated individually. The effectiveness ratings depend on what supervisors and other authorities can demonstrate, and for the private sector that comes down to records showing that:

  • risk assessments reflect actual customers, products and corridors;
  • monitoring alerts are reviewed, closed with reasons, and escalated when they should be;
  • STRs reach the General Directorate of Financial Intelligence (SAFIU) when suspicion is formed;
  • confirmed sanctions matches are frozen without delay.

Saudi Arabia has changed its framework since 2018

Assessors will look at the framework as it stands at the onsite, and several pieces are new.

ChangeDateWhat it means for a SAMA licensee
AML Law amended by Royal Decree M/223April 2026CMS reports governance and enforcement changes, including a statutory role for the AMLPC in setting national risk-based AML policy
Revised AML Implementing Regulations published in Umm Al-QuraJune 2026Pinsent Masons reports that they cover risk assessment, beneficial ownership and group information sharing; see our guide to the 2026 AML amendments
SAMA Rules for the Implementation of Targeted Financial SanctionsDecember 2025Screening at onboarding, before outgoing payments and after each list update, with confirmed matches frozen without delay
SAMA circular 482028988 on integration with the Security Council Resolutions Notification System1 October 2026Addressed to banking, finance, payments, money exchange and credit bureau licensees

The sanctions changes stand out against the 2018 findings, because proliferation-financing sanctions were one of the weak areas then. Expect SAMA to check that licensees can show the screening and freezing process working, with timestamps. CMA-licensed firms fall outside SAMA's sanctions Rules, so they should confirm with the CMA how designations reach them and keep a record of the answer.

An evidence pack built around the 2018 findings

Our guide to the 2026 AML amendments has the checklist for updating policies and procedures. For the evaluation, the useful exercise is different: take each area the 2018 report questioned and decide what record would answer that question today.

2018 findingWhat a supervisor may be asked to showRecord to have ready
Too few STRs, especially on terrorist financingThat firms detect and report suspicionAn STR register covering decisions to file and not to file, with reasons, dates and any follow-up from SAFIU
Weak proliferation-financing sanctionsThat freezes happen without delayScreening logs for onboarding, payments and list updates; records of any matches, freezes and notifications
Money exchangers did not fully understand their risksThat cross-border payment firms understand corridor riskCorridor and counterparty risk ratings, and the monitoring rules that follow from them
Supervision was effective and proactiveThat supervision still finds and fixes problemsInspection findings, the remediation plan and evidence that each item was closed
Beneficial ownership was checkedThat checks still work under the 2026 rulesCorporate customer files showing the natural persons identified and how they were verified

A sample test is worth running before the onsite. Pick five closed alerts, five STR decisions and five sanctions hits at random, and check whether someone outside the team could follow each decision from the file alone. Where they cannot, the gap is in the record or the decision, and either is quicker to fix now than after a supervisor asks.

At a SAMA licensee, the Chief Compliance Officer and the Director of AML/CTF must be Saudi nationals, and payment and fintech companies need SAMA's written non-objection before appointing either. Outside support can strengthen the programme, but it cannot fill those posts. Our guide to outsourcing the MLRO function explains where the line falls.

Where fintech business models draw attention

Cross-border payment and e-money firms sit closest to the 2018 finding on money exchangers. A firm with international flows should be able to explain its corridor risk ratings and show that the required payer and payee information travels with each wire transfer.

Virtual assets are a separate case. The FATF's July 2026 update records Saudi Arabia as having explicitly prohibited virtual assets and virtual asset service providers, and Saudi Arabia has no VASP or crypto-exchange licence. A firm with crypto exposure, such as customers funding exchange accounts abroad, should cover it in its risk assessment and monitoring. Our digital asset perimeter advice covers where those models sit.

After the onsite: what happens until the report is published

The onsite is one stage in a longer process. The assessment team writes up its findings, the report goes to plenary for discussion (provisionally June 2027) and is published after adoption. If the 2018 timetable repeats, publication would follow some months after the plenary. Gaps the report identifies will need fixing afterwards, so the records you put in order now also serve whatever supervisory follow-up the findings lead to.

Saudi Compliance runs independent AML reviews that test the risk assessment, STR and sanctions records against the evidence a supervisor is likely to ask for. See our independent AML review and FATF readiness support.

Sources

General information, not legal advice. Saudi rules change; we confirm every requirement against the regulator's current text before you file.

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