Regulators across the Middle East and Africa are not all moving at the same speed, but they are moving in the same direction. There is less tolerance for “good enough” onboarding and more insistence on evidence, transparency, and ongoing control. The practical message to businesses is simple. Your risk posture has to hold up when it is questioned, not just when it is filed.
For years, many organisations treated compliance as a front-door problem. Collect the paperwork, run checks, approve the counterparty, and move on. In high-growth MEA markets, that model is increasingly viewed as structurally incomplete. Risk changes after approval. Ownership shifts. Control moves. Sanctions evolve. Registries update late. Regulators are responding by tightening expectations around what “knowing your counterparty” means over time.
This is not just a banking story. The same pressure is reaching fintech, trade finance, logistics, energy, real estate, professional services, and any business that relies on cross-border partners, third parties, or regulated financial rails.
The expectation shift in one sentence
Regulators will increasingly expect organisations to prove three things. First, they can identify who ultimately owns and controls an entity. Second, they can explain how they verified that information. Third, they can show they keep it current.
Beneficial ownership that is accurate and kept up to date
Beneficial ownership transparency is moving from best practice to baseline. Global standards already emphasise the need for beneficial ownership information that is adequate, accurate, and up-to-date, and they highlight mechanisms for verification rather than blind reliance on declarations.
Beneficial ownership is where risk hides. In many MEA markets, ownership is layered across holding companies, affiliates, and cross-border vehicles. Control may be exercised indirectly through voting arrangements, financing leverage, or family structures. When due diligence stops at the first visible layer, the organisation is not managing ownership risk. It is a guess.
What regulators will expect next is not perfect visibility in every case. It is a credible effort. Clear logic for how the beneficial owner was identified. Evidence that information was cross-checked. Documented handling of ambiguity where ownership is split, indirect, or intentionally opaque. Timely updates when beneficial ownership changes.
Ongoing monitoring replaces calendar-based comfort
The second expectation is that controls cannot be frozen at onboarding. In MEA, relationships evolve quickly. Businesses expand into new jurisdictions. Ownership and management change. Legal status shifts. Sanctions and geopolitical risks can change fast. Regulators are therefore leaning harder on ongoing monitoring and the ability to retrieve relevant due diligence documentation without delay, including beneficial ownership and the data used for risk assessments.
This is the practical difference between having a file and having control. A file records what was true at a point in time. Control means you can detect when it stops being true.
Many organisations still rely on calendar-based reviews such as quarterly or annual refresh cycles. The next direction of expectation is event-driven monitoring. If directors change, ownership shifts, a counterparty is struck off, a sanctions designation updates, or adverse legal information emerges, that should trigger reassessment. Not in twelve months, but when the change happens.
Proof of verification, not just proof of collection
Another tightening is around verification itself. Regulators are increasingly attentive to the difference between collecting information and verifying it. A customer-supplied document, a declaration, or a self-reported ownership chart is increasingly treated as an input, not a conclusion.
Regulators will expect organisations to demonstrate a verification process. That includes using reliable sources, reconciling discrepancies, validating identity where appropriate, and documenting the reasoning behind the beneficial ownership conclusion. It also includes showing how the organisation decided that the evidence was sufficient for the risk level.
This is where many compliance programmes fail under pressure. Evidence exists, but it is not organised into a defensible narrative. The question from regulators is rarely “Did you receive a document?” The question is “Why did you believe it, and how did you verify it?”
Risk-based approaches must be explainable to a supervisor
Most organisations claim to use a risk-based approach. Regulators increasingly expect you to explain it as an operating model, not a slogan.
In practice, due diligence depth must be proportionate to risk, and the organisation must be able to show the factors that drove the decision.
In MEA, “risk-based” is becoming more demanding because the risk landscape is uneven. Data quality differs by jurisdiction. Ownership transparency varies. Cash intensity and informal business practices can increase risk. Cross-border payments raise complexity. In this context, regulators will increasingly expect organisations to show how they adjust verification intensity based on jurisdiction, sector, transaction profile, ownership structure, and delivery channel.
The practical test is simple. If a supervisor asks why one counterparty received enhanced scrutiny and another did not, can you explain it in plain language, with evidence, and with reference to policy? If not, your model may exist on paper but not in practice.
Auditability and defensibility become frontline requirements
A growing expectation across MEA supervisory regimes is auditability. Not only the outcome of checks, but also the ability to reconstruct what was done, when, and why.
This is where organisations often discover that they do not have a control problem. They have a documentation and data structure problem. Decisions were made but not recorded. Ownership logic was assumed but not captured. Data used for risk scoring was updated but not retained. Evidence exists but is not retrievable quickly.
Regulators and auditors are increasingly focused on whether your programme can survive review, not just whether it can complete onboarding. Expect more attention on record-keeping, version control of key attributes, and consistency across internal systems. Expect questions about whether you can obtain underlying documentation without delay, especially where reliance on third parties is used.
Group structures and related parties will get more attention
As corporate groups expand across jurisdictions, regulators are paying closer attention to group structures, subsidiaries, and affiliates. A single entity does not exist in isolation. It is often part of a network of related parties.
This matters because ownership and control are often exercised at the group level. Risk can also enter through an affiliate, even if the primary entity appears clean. The next expectation is that organisations can identify group relationships, connect entities across the structure, and ensure that screening and monitoring are applied consistently.
If your model still treats each legal entity as a standalone profile, it will increasingly fail in environments where control and exposure sit in the structure.
Technology and data discipline are no longer optional
Regulators are not mandating one technology stack, but the direction of expectation implies stronger data discipline. As requirements shift towards continuous monitoring, ownership mapping, and auditability, purely manual processes become a liability.
This does not mean regulators expect every organisation to build complex systems overnight. It does mean they will be less patient with weak controls justified by operational limitations. The expectation is moving towards structured data, consistent identifiers, reliable screening, and monitoring capabilities that scale with growth.
What businesses should do now?
If you want to meet the next wave of expectations without creating friction, focus on five moves.
First, treat beneficial ownership as a living attribute. Map it, verify it, and monitor it, especially where structures are layered or cross-border.
Second, move from calendar-based reviews to event-based triggers. Define what changes matter and what action follows.
Third, standardise source hierarchy and provenance. Make it easy to show where information came from, when it was verified, and how discrepancies were handled.
Fourth, strengthen auditability. Ensure decisions can be reconstructed. Ensure evidence is retrievable. Ensure risk scoring inputs are stored and explainable.
Fifth, build consistency across systems. Entity resolution is not a nice-to-have. If you cannot uniquely identify a counterparty across procurement, finance, and compliance, you cannot monitor effectively.
The direction is clear
Across MEA, regulators are pushing towards risk integrity under pressure. They are not only asking whether you did checks. They are asking whether your programme can withstand change, scrutiny, and cross-border complexity. Organisations that build around verification, monitoring, and auditability will not only meet expectations. They will move faster, with fewer surprises, in markets where uncertainty is the default.
Sources:
1. Financial Action Task Force
The FATF Recommendations
https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Fatf-recommendations.html
2. Financial Action Task Force
Guidance on Beneficial Ownership and Transparency of Legal Arrangements
https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Transparency-Legal-Arrangements.html
3. Financial Action Task Force
Guidance on Beneficial Ownership of Legal Persons
https://www.fatf-gafi.org/en/publications/Fatfrecommendations/Guidance-Beneficial-Ownership-Legal-Persons.html
4. Central Bank of the UAE Rulebook
Beneficial Ownership Identification and Verification
https://rulebook.centralbank.ae/en/rulebook/325-beneficial-ownership-identification-and-verification
5. UAE Ministry of Economy
Countering Money Laundering, Terrorism Financing and Proliferation Financing
https://www.moet.gov.ae/documents/20121/0/Revised%2BGuidelines%2B-%2BV2%2B%281%29.pdf
6. Saudi Arabian Monetary Authority Rulebook
Beneficial Owner
https://rulebook.sama.gov.sa/en/b-beneficial-owner
7. Greenberg Traurig
KSA Introduces New Ultimate Beneficial Ownership Rules
https://www.gtlaw.com/en/insights/2025/3/ksa-introduces-new-ultimate-beneficial-ownership-rules
