Saudi Arabia

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1. Does Saudi Arabia have a sanctions regime in place?

Yes but not under a distinctive sanctions legislation. It is mostly based on anti-terrorism financing legislations, anti-money laundering legislations, in addition to Saudi Arabia obligations under different international conventions, Ministerial Decrees and Royal Orders and diplomatic decisions.

2. Does Saudi Arabia implement UN sanctions?

Yes.

3. Does Saudi Arabia implement an autonomous sanctions regime?

Yes, in addition to sanctions pursuant to anti-terrorism financing legislations.

In 2011, the Arab League imposed certain sanctions on the Syrian government by virtue of the Decision No. 7442.

Since 2017, certain restrictive measures have also been imposed against the state of Qatar, its government and certain Qatari companies and citizens. This includes the withdrawal of air and land links, restrictions in respect of some lending activities and restrictions in respect of the exportation of some products and the processing of certain payments in Qatari Riyals.

On 5 January 2021 at the Gulf Co-operation Summit, Saudi Arabia formally agreed to end the embargo and aforementioned restrictions that have been imposed on Qatar since June 2017. Following this agreement, Saudi Arabia opened its air, land and sea links with Qatar.

Moreover, although the GCC states recognized that total elimination of the Arab League’s boycott of Israel is a necessary step for peace and economic development of the region in 1996, the boycott of Israel may still be enforced in certain circumstances.

In relation to anti-terrorism financing legislations, sanctions are in place, targeting, for example:

  • Hezbollah
  • Al-Qaeda
  • The Muslim Brotherhood
  • ISIS (the Islamic State in Iraq and the Levant)
  • The Houthis

4. What is the nature of the sanctions regime in Saudi Arabia?

There is no distinctive sanctions regime in Saudi Arabia, but sanctions are enacted either under anti-terrorism financing legislations, being a member state to international organizations which are enforcing sanctions such as the UN and Arab League or distinctive diplomatic decisions such as those previously in place vis a vis Qatar.

Generally, sanctions in place may comprise both economic and non-economic measures, depending on the target country or persons.

5. Does Saudi Arabia maintain a list of sanctioned individuals and entities?

Yes. A Ministry of Interior Decision has previously been issued which confirmed the individuals and entities to which sanctions are applied under anti-terrorism financing legislations. The decision is not publicly available, but it is thought to refer primarily to organizations deemed to be involved in terrorist activities around the world.

In terms of sanctions imposed by international organizations to which Saudi Arabia is a party thereto or to diplomatic based sanctions, there is no Saudi definitive published list of sanctioned individuals and entities.

6. Are there any other lists related to sanctions?

The UN sanctions list and Arabi League sanctions’ decisions should also be referred to as it is Saudi Arabia’s position that it generally implements UN and Arab League sanctions.

7. Does Saudi Arabia have a licensing or authorization system in place?

There is no information available publicly with regard to an authorization procedure. However, to the extent that authorization should be possible, it is likely that any such authorization would have to be obtained at a senior level, either from the Ministry of Foreign Affairs or the Ministry of Interior in Saudi Arabia.

8. What are the consequences for a breach of sanctions in Saudi Arabia?

It is thought that any breach of sanctions that have been imposed by the Saudi Government risk the infringing party being subject to: (i) a fine; (ii) criminal liability; and/or (iii) potentially severe restrictions being imposed by the competent Saudi authority, such as a limitation upon the infringer’s ability to continue operating in Saudi Arabia.

9. Who are the relevant regulators in Saudi Arabia and what are their contact details?

Whilst no specific authority has been assigned to deal with sanctions, it is understood that this area is coordinated primarily by the Ministry of Foreign Affairs in conjunction with the Ministry of Interior, with involvement also from the Saudi Customs Department where necessary.

Ministry of Foreign Affairs Nasseriya Street, Riyadh 11124, Saudi Arabia T: (+966) 11 406 7777, (+966) 11 441 6836 F: (+966) 11 403 0159

National Security Center King Saud Street, E: info@nsc.gov.sa

Ministry of Interior PO Box 2933, Riyadh 11134, Saudi Arabia T: (+966) 11 401 1944 F: (+966) 11 403 1185

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Mohammed AlDhabaan & Partners in association with Eversheds Sutherland (International) LLP,

Office 10-11, Home Offices Complex,

P.O Box 245555,

Riyadh – 11312,

Saudi Arabia

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