CMA Circular 08/2026: How to Report Inaccurate UBO Data
A practical Kuwait CMA UBO discrepancy-reporting guide: identify supported inaccuracies, prepare the MOCI notification and retain review and submission evidence.
تعميم هيئة أسواق المال رقم (08) لسنة 2026 بشأن الابلاغ عن عدم صحة بيانات المستفيد الفعليOfficial Arabic title
- Issued
- 25.05.2026
- Published
- 25.05.2026
- Guide reviewed
- 11.10.2026
- Instrument
- CMA Circular 08/2026
Action at a glance
What this instrument asks you to do
When you have information or documents supporting suspected incorrect or inaccurate customer UBO data, prepare the notification through MOCI's commercial register portal and attach supporting documents. Assign a reviewer, preserve the discrepancy evidence and record the submission. Updating an internal customer file alone does not fulfil the circular's notification instruction.
Source-backed
Stated legal requirements
Requirements below are attributed to the instrument or cited guidance; each item includes its source location.
- 01
Report suspected incorrect or inaccurate customer beneficial-owner identity information when supporting information or documents are available.
Citation · Circular p. 1, reporting paragraph beginning «تدعو هيئة أسواق المال».
- 02
Use the Ministry of Commerce and Industry commercial register portal, ereg.moci.gov.kw, complete the notification form and attach supporting documents.
Citation · Circular p. 1, same reporting paragraph.
Dates and applicability
Timing, grace period and deadline
Timing
Issued 25 May 2026. The instruction is triggered by supported suspected inaccuracy; the circular does not state a separate calendar deadline or an explicit commencement clause.
Grace period
No separate grace period is stated in the reviewed circular. This does not establish that no later relief or amendment exists.
Expit suggested practices
Build a reviewable closure record
These suggested actions are implementation practices, not additional legal requirements.
- 01
Compare the customer declaration, ownership evidence and available commercial-register data; identify the exact disputed fields.
- Suggested owner
- KYC reviewer
- Evidence to retain
- Dated extracts, declaration, ownership documents and a field-by-field discrepancy note.
- Complete when
- The suspected inaccuracy has supporting evidence and an accountable reviewer.
- Expit support context
- Explore IAP document extraction and field comparison; access to external registers requires separate scoping.
- 02
Review the reporting trigger and prepare the MOCI notification with the relevant supporting documents.
- Suggested owner
- Compliance officer and authorised portal user
- Evidence to retain
- Review decision, completed form and attachment manifest.
- Complete when
- The approved package is ready for the authorised user to submit through the correct channel.
- Expit support context
- Document workflows can organise the review package; Expit does not make the legal determination or submit it automatically.
- 03
Submit via the official channel and track the notification separately from internal record corrections.
- Suggested owner
- Authorised portal user
- Evidence to retain
- Portal acknowledgement or other submission evidence, follow-up record and corrected customer-file history.
- Complete when
- Submission is evidenced and any unresolved discrepancy has an owner and documented next action; do not imply MOCI acceptance without confirmation.
- Expit support context
- Explore retaining case evidence and reviewer history; official submission remains with your institution.
Further clarification
Frequently asked questions
How do we close a CMA Circular 08/2026 UBO reporting gap?
Document the supported suspected inaccuracy, obtain compliance review, submit the MOCI notification with attachments and retain evidence. Track any follow-up; an internal data edit is not a substitute for notification.
Does CMA Circular 08/2026 state a grace period?
No separate grace period is stated in the reviewed circular. This does not establish that no later relief or amendment exists.
Can Expit submit UBO notifications to MOCI for us?
No automatic filing is offered by this guide. Expit can help scope document processing and review support; authorised staff must confirm and perform the official submission.
Primary references
Official sources
- CMA Circular 08/2026 — official Arabic document (opens in a new tab)SOURCE 01
Page 1: reporting trigger, portal, supporting documents, legal references and issue date.
- CMA publication and transcription (opens in a new tab)SOURCE 02
Publication date and readable Arabic transcription; attached original takes precedence.
Read with care
Enforcement and limitations
Enforcement stated in source
The final substantive paragraph references sanctions under Law 7/2010 and Law 106/2013, as amended. It does not prescribe a fine amount in this circular.
Limitations of this guide
This is customer discrepancy reporting, not simply registration of your company's own UBOs. Portal authorisation and the current notification form must be confirmed by the submitting institution. Do not interpret a suspected discrepancy as proof of wrongdoing.