Saudi Arabia

Overview

Saudi Arabia's capital markets regulator is the Capital Market Authority. It is a CMA — and this is the regulator people mean when they use that acronym in a Gulf context. It is not the UAE regulator; the UAE federal equivalent is the SCA.

What a UAE firm needs to know

There is no passporting between the UAE and Saudi Arabia. A VARA, FSRA or DFSA licence confers nothing in the Kingdom. Serving Saudi clients from Dubai is a cross-border question governed by Saudi law, and the fact that a client approached you does not automatically make it lawful.

The practical route

Most firms take one of three positions: they stay out of the market entirely and document that decision; they rely on a narrow reverse-solicitation analysis and police it with hard controls rather than a disclaimer; or they establish locally.

The middle option is where firms get into trouble, because reverse solicitation is a narrow doctrine that is defeated by marketing, by relationship management, and by a sales team with targets.

What to verify before relying on anything here

The Kingdom's position on virtual assets has developed through sandbox arrangements and supervisory statements rather than a single consolidated regime. Anything material should be confirmed against the current CMA and SAMA positions at the time of the decision.

How we help

We advise on market access before a sales team is pointed at a country, document the basis on which clients in each market are accepted or refused, and build the controls that make that basis hold. Where a second licence is genuinely needed, we run it.