Saudi Arabia: SAMA’s remittance centres work through a membership, with a capped exception for visitors and pilgrims receiving money
An individual sending money through a Saudi remittance centre need not hold a bank account, but must hold a membership. The Saudi Central Bank (SAMA) builds its remittance centre rules around this “remittance membership”: a contract, a number linked to the customer’s ID, and a record of every transfer. In our reading, much of the financial crime control depends on that record.
This briefing works from SAMA’s Guide to Rules Governing Banks’ Remittance Centers, issued by circular No. 381000063572 dated 14/06/1438H, corresponding to 12 March 2017, and shown as In-Force. The circular told all banks to adhere to it from 9 July 2017. It reads the Guide against the AML/CTF Guide of 17 November 2019 and the Account Opening Rules.
Wire transfer data rules in general are covered in our briefing of 29 October. This one is about what is particular to remittance centres.
Who it covers, and how it sits with later rules
Section 1.1 applies the Guide to all operations of banks’ remittance centres and licensed remittance companies. SAMA is the supervisor and may act on violations, including through penal fees, under the Banking Control Law.
The one change the Guide itself marks as an amendment is to section 4, working hours (circular No. 41/2304), which is outside this briefing. The Guide is older than the AML/CTF Guide and its reference list still names the 2012 AML rules. Section 5 requires compliance with all SAMA circulars on remittances, and item 10 of section 10 points to SAMA’s AML/CTF rules. The AML/CTF Guide does not mention remittance centres by name, and neither text says how the two rank.
What a membership is
Section 3 defines the membership as a register at the centre, set up by a “Remittance Membership Opening Agreement” signed by the centre and the customer. Under section 9.1 the customer receives a membership card with a personal number tied to an automated system that holds the personal details, photo ID and signature. For each transaction the customer presents the number and the original ID.
Section 9.2 sets the opening conditions. The ones that matter most to a compliance reader:
- In person. The customer opens the membership personally, subject to the visit cases in the Account Opening Rules.
- No companies. Legal persons may not open a membership. They need a bank account and must run all their transactions through it.
- One person. A membership may not be shared, treated as a current account or used for a purpose other than the one it was opened for.
- Minors. A person under 18 Hijri years needs the approval of a guardian or curator.
- New expatriates. A person holding a temporary residence permit under a work visa may be given a membership for three months. It is then frozen until a valid resident ID is issued.
- The customer’s confirmation. The form carries an item confirming that the customer is the real beneficiary of the membership and has a direct relationship with the beneficiaries of the remittances.
- Expected activity. The centre determines the amounts and numbers of expected monthly or yearly remittances, in and out, and assesses them against the customer’s monthly income.
The centre manager approves the opening after verifying the customer’s information against the volume and nature of their activity (section 9.4). Name and ID number go in, in Arabic and English, as mandatory fields.
Details must be updated when the ID expires or after five years at most, whichever is earlier. They must also be updated when documents or financial operations are suspected, or when transactions stop matching the information given or the pattern of behaviour changes (section 9.3).
The Account Opening Rules take the same line from the bank’s side. Paragraph 14.1 allows outgoing transfers only for customers holding an account, and accepts the customer number in the Express Transfers System in place of an account for customers of that service, which we read as the remittance centre service. The membership account must also be linked to transaction monitoring systems.
The exception: receiving, not sending
Section 10 opens with the rule that money transfers for customers are executed through membership only. Item 3 then allows centres to receive transfers for temporary customers who are not entitled to a membership: visitors holding a visa or temporary residence permit, and pilgrims and Umrah performers. It has these conditions:
- no more than SAR 5,000 or its equivalent for a single transaction;
- a total of no more than SAR 50,000 or its equivalent in one year;
- a copy of the passport, including the page with the entry visa;
- attention to other details, such as a home country address, a contact number or point of contact in Saudi Arabia, and the signature;
- clarification of how the recipient is related to the sender.
The same figures appear in paragraph 5.8 of the AML/CTF Guide, which allows an occasional customer currency exchange, money transfer and cheque cashing within them, with no mention of direction. In our reading, a remittance centre should apply the narrower item 3, because the Guide written for it allows receipt only.
What travels with the transfer, and what is kept
Item 11 lists what an outbound remittance carries or includes. Three points stand out: the originator’s membership number, the purpose in detail, and the type of relationship with the beneficiary. The beneficiary’s address in their home country is required too, and date of birth if available.
Three record-keeping duties sit alongside it:
- each transfer is recorded in the customer’s membership record, with detail (item 6);
- names of senders and beneficiaries, amounts and dates are documented in the registers and automatically linked to the customer’s ID number (item 8);
- SAMA, in coordination with the Banking Supervision Department, receives a monthly statement of all money transfers carried out with internal and external financial institutions, banks and money changers (item 9).
Domestic remittances go through SARIE only (item 2). The centre records the sender’s name and account number for fast retrieval by competent authorities (item 27).
When the originator’s information is missing
Item 14 sets out a sequence for a wire that arrives without complete originator information:
- obtain the information from the correspondent or the transfer service provider;
- reject the transaction and return the transfer if the correspondent does not respond;
- report to the General Directorate of Financial Intelligence (SAFIU) if the transaction is suspicious and the financial institution has not responded;
- document the decisions and reasons in writing, and keep those records for ten years.
Item 21 follows through. With repeated gaps and lack of cooperation, centres assess the relationship and consider restricting or ending it. Under item 22, a money laundering or terrorist financing suspicion about a correspondent or transfer provider itself goes to SAFIU immediately and is documented.
Item 20 covers technical limits on carrying the information into a linked domestic transfer. The intermediate centre keeps everything it received for ten years, and answers inquiries from the correspondent bank or authorities within a period not exceeding 72 working hours. The Guide does not define that term. It is also a different case from the three working days in paragraph 14.4 of the AML/CTF Guide, which applies to the information on a domestic transfer.
Screening, monitoring and politically exposed customers
The Guide asks centres to:
- reject remittances for countries with which dealings are prohibited (section 5);
- check the names of individuals, entities and banks that originate or receive transfers, or act as intermediaries, against local and international lists, and act on the result (items 28 and 29);
- monitor all transfers, in and out, for abnormal patterns with no clear economic or legal purpose, and document the results in writing (item 25);
- strengthen due diligence on remittances linked to politically exposed persons (item 15), and on funds moving from or to countries against which the FATF has issued warnings (item 24).
Charities: two tests
Item 16 rejects remittances in or out of the Kingdom for charitable or non-profit organisations, except bodies allowed to do so under the Account Opening Rules. Paragraphs 14.10 and 14.11 of the AML/CTF Guide, covered in our wire transfer briefing, frame the bar by charitable purpose, whatever the source of funds or the beneficiary, subject to a footnote on SAMA approvals. One test looks at who is receiving, the other at why. In our view a remittance centre needs both.
Ending relationships, one case at a time
Section 9.4 says the relationship is ended when the centre cannot verify the sources of transactions, doubts the customer’s identification details, or the customer keeps using the membership for other purposes. Section 9.6 sets the limit: entire categories of customers may not be cut off or absolutely restricted to avoid managing risk, or because returns are low, without considering other mitigation for individual customers and treating risk case by case.
Transfer service providers
Section 11 covers contracts with money transfer service providers. Among its requirements, the provider must be internationally recognised and licensed in its home country, and money transfer must be part of its core business. Banks ask SAMA for prior non-objection under the outsourcing rules, attaching the final draft contract, a company brief and a certificate of AML/CFT compliance. The contract must commit the provider to Saudi law and SAMA’s rules, UN lists and FATF warning notices, and to give SAMA any information it asks for. The provider’s system is linked to the bank’s, so that all its transactions show in the bank’s system. Item 23 of section 10 requires full information on the parties to the transfers a provider executes.
Reading the English against the Arabic
SAMA’s rulebook carries the Guide in Arabic too. The readings below are our own translations.
- “Temporary customers”. The Arabic of item 3 says العملاء العابرين. The AML/CTF Guide’s Arabic uses the same word beside its term for “occasional customer”: عميل عارض (عابر). In our reading, these are the same customers under two English names.
- “Confirming full knowledge”. In item 11 the Arabic is مع الإقرار بالمعرفة التامة بالمستفيد: with an acknowledgement of full knowledge of the beneficiary. In our reading that is a statement by the customer, closer to the declaration in paragraph 14.2 of the AML/CTF Guide than the English suggests.
- “72 working hours”. The Arabic is the same: ساعة عمل, hours of work.
- “Real beneficiary”. Both languages use one term, المستفيد الحقيقي, for the person controlling a membership (item 5) and for the person receiving the money (the heading of item 11(b)). Read each in its context.
What to do with it
These are our suggestions, not SAMA’s.
- Check the opening form against section 9.2. Look for the customer’s confirmation and expected activity, then test whether the expected figures are ever compared with actual transfers.
- Set item 3 as a system rule. Block sending for temporary customers, and enforce both SAR limits across branches.
- Track the three-month memberships. Confirm that a temporary-permit membership freezes without manual action.
- Write the item 14 sequence into operations. Include how long you wait for a correspondent before you return the funds, which the Guide leaves open, and keep the reasons.
- Decide what 72 working hours means for you. Record the reading, and take the cautious one if in doubt.
- Run charity checks on both the recipient and the purpose.
- Review any exit from a customer group against section 9.6. Keep the reasoning for each case.
Sources
This article draws on the following sources. Follow the links for the original text.
- Saudi Central Bank (SAMA) — Guide to Rules Governing Banks’ Remittance Centers, circular No. 381000063572, 12 March 2017 (entire section)
- Saudi Central Bank (SAMA) — Guide to Rules Governing Banks’ Remittance Centers, Arabic text
- Saudi Central Bank (SAMA) — Circular Re. Guide to Rules Governing Banks’ Remittance Centers
- Saudi Central Bank (SAMA) — The AML/CTF Guide, circular No. (18318/486), 17 November 2019 (entire section)
- Saudi Central Bank (SAMA) — The AML/CTF Guide, Arabic text
- Saudi Central Bank (SAMA) — Account Opening Rules (entire section)
For information only. This briefing is not legal advice: check the cited sources and take advice on your own position.
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