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IRU Circular 18/2026Insurance Regulatory Unit

IRU Circular 18/2026: Prepare UBO Evidence for Inspection

How IRU-supervised firms can adopt the updated beneficial-owner guidance and prepare evidence of customer identification and complex ownership review for inspection.

تعميم رقم (18) لسنة 2026 بشأن تحديث الدليل الارشادي لمفهوم المستفيد الفعليOfficial Arabic title

Issued
02.09.2026
Published
03.09.2026
Guide reviewed
11.10.2026
Instrument
IRU Circular 18/2026

Action at a glance

What this instrument asks you to do

Obtain the updated beneficial ownership guidance referenced by IRU, map it to your customer identification and complex-structure review procedures, and keep evidence showing how the real beneficial owners were identified. The circular says implementation will be followed up during IRU inspections. A declaration without a reviewable ownership and control rationale is not a complete remediation record.

Source-backed

Stated legal requirements

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

  1. 01

    Addressed firms must comply with the updated beneficial-owner guidance approved by the national AML/CFT/proliferation-financing committee.

    Citation · Circular p. 1, central paragraph beginning «يتعين».

  2. 02

    The guidance supports reaching the real beneficial owner for customer identification and legal arrangements involving complex structures; IRU will follow up on implementation during inspections.

    Citation · Circular p. 1, same central paragraph.

Dates and applicability

Timing, grace period and deadline

Timing

Document issued 2 September 2026; published online 3 September 2026. The reviewed circular states the compliance instruction and inspection follow-up but does not include an explicit date-of-issuance commencement clause or a separate calendar deadline.

Grace period

No separate grace period is stated in the reviewed circular. This is not a claim that no subsequent extension or amendment exists.

Expit suggested practices

Build a reviewable closure record

These suggested actions are implementation practices, not additional legal requirements.

  1. 01

    Obtain and version the updated guidance referenced by IRU; compare it against your current procedures.

    Suggested owner
    AML policy owner
    Evidence to retain
    IRU-applicable guidance version, clause-level gap assessment and policy approval.
    Complete when
    The authoritative version is confirmed and relevant gaps have an owner and action.
    Expit support context
    Explore document review and version-controlled evidence; no automated legal interpretation.
  2. 02

    Prioritise customer files with complex ownership or legal arrangements and review the basis for identifying the real beneficial owners.

    Suggested owner
    Corporate KYC reviewer and compliance specialist
    Evidence to retain
    Ownership/control records, supporting identity documents and reviewer reasoning.
    Complete when
    The identification rationale is supported, or the unresolved question is escalated for qualified review.
    Expit support context
    Explore extracting submitted document fields and organising review evidence.
  3. 03

    Sample-test retrieval of the identification evidence and documented remediation for an inspection.

    Suggested owner
    Quality assurance and inspection liaison
    Evidence to retain
    Sample-test record, evidence index and open-issue register.
    Complete when
    The institution can explain the reviewed identification process and disclose unresolved gaps without claiming inspector acceptance.
    Expit support context
    Explore IAP document extraction, review-package preparation and traceable case records. Human approval, legal interpretation and official submissions remain with your institution; integrations require separate technical scoping.

Further clarification

Frequently asked questions

How do we address IRU Circular 18/2026 before an inspection?

Obtain the IRU-applicable updated guidance, map it to your procedures, review relevant customer files and retain evidence and reviewer reasoning. The circular explicitly says implementation will be followed up during inspections.

Does this guide verify every clause of the underlying UBO guidance?

No. The official one-page IRU circular was reviewed. Its referenced full guidance still needs to be obtained and checked for the institution's clause-level assessment; detailed rules are not inferred here.

Primary references

Official sources

  1. IRU Circular 18/2026 — official Arabic document (opens in a new tab)

    Page 1: updated-guidance instruction, inspection follow-up, legal warning and issue date.

    SOURCE 01
  2. IRU official publications index (opens in a new tab)

    Website publication date; not a substitute for the document's issue date or clauses.

    SOURCE 02

Read with care

Enforcement and limitations

Enforcement stated in source

The closing paragraph warns of legal accountability under Insurance Law 125/2019, its Executive Bylaws and relevant IRU instruments and laws. No specific fine amount is stated here. The warning also expressly cites AML Law 106/2013.

Limitations of this guide

The reviewed IRU download is the one-page circular, not the full underlying guidance. Obtain the IRU-applicable updated guidance and confirm its version before a clause-by-clause assessment. This guide does not infer detailed thresholds, exemptions or deadlines from the circular, or assume that a CMA attachment has identical IRU applicability.