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CMA Circular 14/2026Capital Markets Authority

CMA Circular 14/2026: Implement the Updated UBO Guidance

How CMA-licensed firms can review the August 2026 beneficial ownership guidance, address ownership changes and Waqf arrangements, and build verification evidence.

تعميم هيئة أسواق المال رقم (14) لسنة 2026 بشأن تحديث الدليل الإرشادي لمفهوم المستفيد الفعليOfficial Arabic title

Issued
26.08.2026
Published
26.08.2026
Guide reviewed
11.10.2026
Instrument
CMA Circular 14/2026

Action at a glance

What this instrument asks you to do

Adopt the updated beneficial ownership guidance from 26 August 2026, compare it with your existing UBO procedures, and address change identification, MOCI notification and Waqf arrangements. Review affected customer files and retain the ownership, identity and control evidence behind each decision. A 25% ownership check alone is not a complete UBO assessment.

Source-backed

Stated legal requirements

Requirements below are attributed to the instrument or cited guidance; each item includes its source location.

  1. 01

    Work with the updated attached guidance from the circular's date of issuance.

    Citation · Circular p. 1, introductory paragraph; issued 26 August 2026.

  2. 02

    The update adds procedures for identifying changes relating to beneficial owners in legal persons or arrangements and reporting to MOCI through its notification mechanism.

    Citation · Circular p. 1, first bullet; guidance section 4.

  3. 03

    The update amends and adds Waqf-related provisions and an illustrative property-Waqf example.

    Citation · Circular p. 1, second bullet; English guidance paragraphs 10–13 and 58.

  4. 04

    The guidance addresses ownership, control through other means and the senior-managing-official fallback; verify both the person's identity and their status as beneficial owner.

    Citation · English guidance paragraphs 52–59 and 68–75.

Dates and applicability

Timing, grace period and deadline

Timing

Explicitly effective from issuance: 26 August 2026. Do not replace this date with a later internal rollout date.

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.

  1. 01

    Version the updated guidance and compare your policy, customer forms and review process against the ownership, control and legal-arrangement provisions.

    Suggested owner
    AML policy owner
    Evidence to retain
    Source version, clause-mapped gap register and approved policy changes.
    Complete when
    Each relevant gap has an owner, a remediation action and an approved implementation record.
    Expit support context
    Explore document classification and controlled review workflows; policy interpretation remains with compliance.
  2. 02

    Review affected ownership chains, control rights and Waqf files; distinguish identity verification from evidence of ownership or effective control.

    Suggested owner
    Corporate KYC team and qualified specialist
    Evidence to retain
    Ownership/control analysis, identity evidence, relevant deeds or agreements and reviewer rationale.
    Complete when
    The identified natural persons and the basis for identification can be explained from retained evidence, or the unresolved case is escalated.
    Expit support context
    IAP can support extraction from submitted documents; ownership/control conclusions require human review.
  3. 03

    Implement change detection and discrepancy-notification review, then sample-test the revised process.

    Suggested owner
    Compliance officer and quality assurance
    Evidence to retain
    Change logs, notification decisions, submission records where applicable and sample-test results.
    Complete when
    A reviewer can trace a detected change through its assessment, required notification and follow-up.
    Expit support context
    Explore structured case records and review history; do not assume a live MOCI integration.

Further clarification

Frequently asked questions

When did CMA Circular 14/2026 become effective?

The circular explicitly says the updated guidance is to be applied from its issuance date, 26 August 2026.

Is checking 25% ownership enough to identify a UBO?

No. The attached guidance also addresses control through other means and a senior-managing-official fallback when earlier identification steps do not identify a beneficial owner. Apply the full relevant process with human review.

What evidence helps close an updated UBO guidance gap?

Keep the versioned guidance, policy gap analysis, ownership and control documents, identity verification evidence, reviewer reasoning and change/notification records where applicable. These are suggested implementation records, not a guarantee of regulatory acceptance.

Primary references

Official sources

  1. CMA Circular 14/2026 — official Arabic document (opens in a new tab)

    Page 1: effective date, two highlighted changes and Article 15 reference.

    SOURCE 01
  2. CMA attached beneficial ownership guidance — English (opens in a new tab)

    August 2026 guidance, especially paragraphs 52–59, 68–75 and section 4; selected provisions reviewed.

    SOURCE 02
  3. CMA publication — Arabic guidance attachment also available (opens in a new tab)

    Official publication and links to both language versions.

    SOURCE 03

Read with care

Enforcement and limitations

Enforcement stated in source

Circular p. 1 expressly refers to measures and sanctions under Article 15 of Law 106/2013, without prejudice to criminal penalties under that law. No fine amount is asserted here.

Limitations of this guide

This guide summarises selected changes, not every clause of the attached guidance. English labels are explanatory; consult the official Arabic text and applicable framework. Complex control rights and Waqf arrangements require a qualified reviewer, not an automated ownership-percentage decision.