Saudi Arabia complies with UN sanctions and has domestic sanctions-related measures. This guide covers applicable lists, screening, and compliance steps. See AML compliance, anti-bribery, and corporate compliance checklist.
Overview
Saudi Arabia implements UN Security Council sanctions resolutions and may publish or use local lists of designated persons and entities. Dealing with designated parties (e.g. providing funds, services, or doing business) can be prohibited and punishable. Financial institutions and other AML-obligated entities must screen; all businesses are well advised to avoid designated parties. See AML compliance and corporate governance.
UN and Saudi Lists
The UN Security Council maintains sanctions lists (e.g. Al-Qaida, ISIL, country-specific). Saudi Arabia implements these through domestic law and regulations. The Saudi list or consolidated list may be published by the relevant authority (e.g. the Anti-Money Laundering Permanent Committee or the Financial Intelligence Unit). Stay updated: lists change frequently. See AML compliance for the supervisory framework.
Screening and Procedures
Obligated entities must screen customers and transactions against applicable sanctions lists (and PEP/sanctions as part of CDD). Screening should be ongoing (e.g. at onboarding and periodically, and against updated lists). Non-obligated entities should still screen counterparties and avoid designated parties. Document your screening process and act on matches (e.g. block, report). See beneficial ownership and PDPL when handling screening data.
Who Must Comply
All persons and entities in Saudi Arabia must not violate sanctions. AML-obligated entities (banks, insurers, etc.) have explicit obligations to screen and report. See AML compliance. Other businesses (e.g. trading companies) should still check counterparties to avoid dealing with designated parties and to protect themselves from reputational and legal risk. See contract law for clauses on sanctions compliance.
Consequences of Breach
Breaching sanctions can result in criminal penalties, fines, freezing of assets, and loss of licence. Banks and correspondent relationships can be affected. Reputational damage is significant. Take screening seriously and train staff. See AML compliance and corporate compliance checklist.
Practical Steps
Implement a sanctions policy; use screening tools or services to check names against UN and Saudi lists; screen at onboarding and when lists are updated; define escalation for potential matches; and train staff. For cross-border trade, consider screening shipping and payment parties. See customs and logistics. Document decisions and keep records consistent with AML and PDPL.
Sanctions Checklist
- Identify applicable sanctions lists (UN, Saudi, and any other relevant jurisdictions).
- Implement screening for customers, counterparties, and (where relevant) transactions. See AML.
- Define procedures for matches (block, report, escalate); train staff.
- Update screening when lists change; keep records. See PDPL.
- Include sanctions compliance in contracts and due diligence. See contract law and corporate compliance checklist.