Saudi Arabia

Global sanctions guide

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

Yes.

  1. Does Saudi Arabia implement UN sanctions?

Yes.

  1. Does Saudi Arabia implement an autonomous sanctions regime?

Yes. The following sanctions are in place, targeting:

  • the Netherlands, namely
    • restrictions on admission of Dutch nationals into Saudi Arabia
    • a ban on the provision of services by Dutch companies
  • Hezbollah
  • Al-Qaeda
  • The Muslim Brotherhood
  • ISIS (the Islamic State in Iraq and the Levant)

In addition, two specific Saudi banks, Al-Rajhi Bank and Bank Al-Ahli (or National Commercial Bank as it is also otherwise known) have imposed their own entity-specific sanctions against the state of Sudan, by cutting off dealings with this country.

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

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

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

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

Yes. The Ministry of Interior Decision has previously been issued which confirmed the individuals and entities to which sanctions are applied. The Decision is not publicly available, but it is thought to refer primarily to organisations deemed to be involved in terrorist activities around the world.

  1. Are there any other lists related to sanctions?

Yes. The UN sanctions list should also be referred to as it is Saudi Arabia’s position that it implements UN sanctions.

  1. Does Saudi Arabia have a licensing or authorisation system in place?

There is no information available publicly with regard to an authorisation procedure.

However, to the extent that authorisation should be possible, it is likely that any such authorisation would have to be obtained at a senior level, either from the Ministry of Foreign Affairs or the Ministry of Interior in Saudi Arabia.

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

It is thought that the consequences for a breach of sanctions are: (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.

With respect to UN sanctions, the infringing party may be subject to substantial fines, as well as liability in accordance with the local law applicable where the infringing party has its operations.

  1. 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

Ministry of Interior
PO Box 2933,
Riyadh 11134,
Saudi Arabia

T: (+966) 11 401 1944
F: (+966) 11 403 1185

Contributor law firm

Dhabaan and Partners (in association with Eversheds), Home Offices, P.O Box 245555, Riyadh – 11312, Saudi Arabia