October 15, 2026 · Jurisdiction Briefing

Saudi Arabia: SAMA points financial institutions to Wathq, the non-profit centre and the Awqaf authority to verify the beneficial owner

Between March and July 2026 the Saudi Central Bank (SAMA) issued circulars on one narrow question: where a financial institution should go to check who the beneficial owner of a customer is. Each circular names a different official body and a different type…

Illustration for “Saudi Arabia: SAMA points financial institutions to Wathq, the non-profit centre and the Awqaf authority to verify the beneficial owner”

Companies. Circular No. 472047799, dated 9/3/2026 (20/9/1447H), on technical integration with the “Wathq” service of the Ministry of Commerce.
Private associations and foundations. Circular No. 472058161, dated 31/5/2026 (14/12/1447H), on the inquiry service of the National Center for Non-Profit Sector.
Awqaf (endowments). Circular No. 482008022, dated 14/7/2026 (29/1/1448H), on the services of the General Authority for Awqaf.

SAMA’s rulebook shows each one as In-Force and marks each English text as a translated document. Each circular’s rulebook page lists the other two under related content, which is a good reason to read them together.

Our 15 September comparison looked at beneficial ownership registers across six jurisdictions. This briefing stays in Saudi Arabia and looks at what the supervisor now expects an institution to do with them.

The duty the circulars build on

The duty to identify the beneficial owner is older than these circulars. Each one refers to the Implementing Regulation to the Anti-Money Laundering Law, issued by Presidency of State Security Decision No. (14525) dated 19/02/1439H. The May and July circulars add that it obliges financial institutions to apply due diligence measures, particularly in identifying and verifying the beneficial owner.

The Regulation defines the beneficial owner as any natural person who ultimately owns or exercises direct or indirect control over a customer, or on whose behalf a transaction is being conducted. Article 7/2 says due diligence measures are based on risk and lists what they comprise at a minimum. Identifying the beneficial owner is on that list, and the article sets out how:

Legal persons. Identify, and take reasonable measures to verify, the natural person who ultimately owns or controls 25% or more of the legal entity’s shares.
Where that does not give an answer. If no controlling ownership interest exists, or there is doubt about whether the controlling shareholder is the beneficial owner, the institution looks to the natural person exercising control through other means and, as a last means, to the natural person who holds the position of senior managing official.
Legal arrangements. Identify, and take reasonable measures to verify, the persons the English text calls “the endower, beholder, the beneficiaries or classes of beneficiaries”, and any other natural person exercising ultimate effective control over the arrangement.

The standard of verification is stated in the same article: the institution uses information and data obtained from a reliable source, such that it is satisfied it knows who the beneficial owner is. Article 7/3 sets the timing. The identity of the customer and the beneficial owners is verified before or during the course of establishing a business relationship or opening an account. Where the money laundering risk is low, the same article lets an institution complete verification of the customer’s identity as soon as practicable afterwards, if postponing it is essential not to interrupt the normal conduct of business, and it must then apply appropriate measures to manage the risk.

The 2026 circulars tell institutions which sources SAMA has in mind.

Companies: the Wathq service

The March circular reports that the Ministry of Commerce has launched a service to inquire about the disclosed beneficial owner data of companies registered with it. The service is available through “Wathq”, and the circular describes it as giving access to updated and approved data. Alongside the AML Law, the Law on Combating the Financing of Terrorism and the Implementing Regulation, the circular cites the Ultimate Beneficial Owner (UBO) Rules issued by Minister of Commerce Decision No. (99) dated 05/06/1447H.

SAMA asks for two things.

First, technical integration with Wathq to verify the identity of the beneficial owner, in full compliance with all relevant conditions, controls and requirements.

Second, a notification. A financial institution must notify the Ministry of Commerce, via the platform, where a beneficial owner has not been disclosed by the company or where discrepancies in the beneficial owner information are identified. The trigger is the institution’s own work: the circular says the notification is based on the outcomes of the due diligence measures conducted.

The circular takes effect from the date of its publication on SAMA’s website.

Private associations and foundations: the non-profit centre

The May circular reports that the National Center for Non-Profit Sector has launched a service that lets financial institutions inquire about beneficial owner information from private associations and foundations, through the Center’s website. SAMA emphasises the necessity of using that service to fulfil due diligence requirements towards customers that are private associations and foundations.

The follow-up is worded differently from the companies circular. Where an undisclosed beneficial owner exists, or where discrepancies are identified in the information the association or foundation provided, the institution must apply the due diligence measures it has in place, in line with the requirements for reporting suspicious transactions. The Center is to be notified by email, at an address the circular gives.

Awqaf: the General Authority for Awqaf

The July circular reports that the General Authority for Awqaf has made channels available for financial institutions to access beneficial owner data relating to Awqaf, and lists them:

Technical integration and linkage with the Authority’s systems. The institution contacts the Authority’s Data Management Office by email to request the beneficial owner data sharing forms, which are then approved by both the institution and the Authority.
The Wakf Certificate Verification service on the Authority’s website.
The list of all registered endowments that the Authority makes available to the public on its website.

The circular says access is through any of these channels. SAMA emphasises the necessity of using them to verify beneficial owner data related to Awqaf, and of notifying the Authority of any cases where discrepancies in that data are identified. The notification goes on the designated discrepancy reporting form available on the Authority’s official website.

Side by side

	Companies	Private associations and foundations	Awqaf
Circular	No. 472047799, 9/3/2026	No. 472058161, 31/5/2026	No. 482008022, 14/7/2026
Source of the data	Ministry of Commerce, through “Wathq”	National Center for Non-Profit Sector, through its website	General Authority for Awqaf, through any of the listed channels
What triggers a notification	A beneficial owner not disclosed by the company, or discrepancies	An undisclosed beneficial owner, or discrepancies	Discrepancies in beneficial owner data
How to notify	Via the platform	By email to the Center	On the Authority’s discrepancy reporting form
Action from	Date of publication on SAMA’s website	Date of publication on SAMA’s website	Date of publication on SAMA’s website

Two points are worth noticing in that table. The Awqaf circular speaks only of discrepancies and does not use the “undisclosed beneficial owner” wording of the other two. And none of the circulars gives a time limit for sending the notification.

Each circular also gives the email address of SAMA’s Financial Integrity General Department for institutions that run into difficulties with implementation or with the service.

When the official record and your file disagree

The circulars place two limits around this step.

The first is suspicious transaction reporting. The companies and Awqaf circulars say the notification is made without prejudice to the requirements for reporting suspicious transactions in the relevant laws and regulations. Telling the Ministry or the Authority about a discrepancy is therefore a separate step from a report to the General Directorate of Financial Intelligence, and does not replace it. Article 15, as set out in the Implementing Regulation, requires an institution that suspects or has reasonable grounds to suspect that funds are the proceeds of crime or related to money laundering to report promptly and directly to the Directorate.

The second is data protection. In all of the circulars the step is to be taken in a manner that does not contravene the Personal Data Protection Law, its implementing regulations and SAMA’s instructions.

One more provision belongs next to these. Under Article 7/8 of the Implementing Regulation, an institution that is unable to comply with the due diligence obligations may not open the account, establish the business relationship or carry out the transaction. For an existing customer it shall terminate the relationship. In all cases it shall consider submitting a suspicious transaction report. A beneficial owner that cannot be established after the register check is a due diligence question first, and a notification question second.

Reading the English against the Arabic

The English texts are translations, and some wording points matter here.

“Importance” or “necessity”. The English Wathq circular says SAMA “emphasizes on the importance of implementing technical integration”. The Arabic text uses ضرورة, necessity, which is the word the English uses in the other two circulars. Read the Wathq integration as something SAMA expects, not as a suggestion.
“UBO” is the same term. The English Wathq circular speaks of the Ultimate Beneficial Owner (UBO). The Arabic title uses المستفيد الحقيقي, the same term the Arabic Implementing Regulation uses for the beneficial owner.
“Reliable” or “reliable and independent”. The English Article 7/2 speaks of information and data from a reliable source. The Arabic says a reliable and independent source. The Arabic also names the parties to a legal arrangement as المنشئ and الناظر, the person who establishes it and its administrator, where the English has “endower” and “beholder”.

What to do with it

Map each customer type to its source. Companies registered with the Ministry of Commerce, private associations and foundations, and Awqaf each have a named channel. Write them into the onboarding procedure, with the fallback for customers that fall outside all of them.
Keep doing your own due diligence. The Wathq circular makes the institution’s due diligence findings the trigger for a notification. The official record is something you compare your file against. It does not replace the file.
Give discrepancies an owner. Decide who compares the official record with the customer’s declaration, who sends the notification on each route, and where the evidence of it is kept.
Run the suspicion test separately. A discrepancy goes to the Ministry, the Center or the Authority. Whether it is also suspicious is a different decision, made under the reporting rules and recorded on its own.
Start the integrations. The Wathq integration and the Awqaf data sharing forms both involve another body. If a channel does not work, the circulars name the SAMA department to tell.

Sources

This article draws on the following sources. Follow the links for the original text.

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