Saudi source-of-funds: what the CIUs actually expect

A Saudi national applies for a Caribbean CBI passport. The application clears initial intake within 48 hours. Eight weeks later the DD report comes back with a query on the source of funds for a 2019 dividend distribution from a family-owned trading company. The applicant’s Riyadh accountant provides a statement. The DD firm rejects it as insufficient.

This sequence is now the most common single cause of a Caribbean file slipping its calendar in our office. The DD firms are not being unreasonable. They are responding to a 2023-2024 tightening of FATF Mutual Evaluation guidance that hit Caribbean CIUs harder than most jurisdictions, because the CIUs sit on a list of programmes the OECD watches closely. The CIUs have, in turn, pushed the burden onto their outsourced DD vendors, who have pushed it onto applicants.

Here is the working picture in 2026 for applicants out of Saudi Arabia, and the documentation pack we now build into every Gulf-origin file from the start.

What the CIUs actually ask

The four Caribbean programmes (Antigua, Dominica, Grenada, St. Kitts) outsource due diligence to a small number of UK-based firms (Thomson Reuters, Exiger, Sapphire being the most common). These firms operate from a standard checklist that has been substantially the same since 2023. For a Saudi applicant they expect, at minimum:

1. A complete reconstruction of the source of the contribution funds. Not just “dividends from family business.” The full chain: which entity paid the dividend, in which year, what underlying revenue justified that dividend, and how that revenue itself was generated. This typically goes back three to five years in our experience.

2. Audited financial statements of any entity in the chain. Saudi private companies are not always audited. For files where the entity is below the audit threshold, the DD firm wants a third-party review report or, failing that, a bank attestation of historical cash flows.

3. Cross-evidence of personal wealth. Bank statements covering at least 24 months, with explanations for any non-recurring inflows above SAR 100,000 equivalent.

4. ZATCA tax compliance evidence. Zakat, Income Tax and Customs Authority issues a tax-compliance certificate (شهادة الإلتزام الضريبي) that the DD firms now request as standard. This is a five-minute task for the applicant if their company is compliant; a multi-week task if there are unresolved filings.

5. For inherited wealth. A copy of the original inheritance instrument, certified by a Saudi notary, plus an explanation of how the inherited assets generated the funds being contributed. Inheritance documentation that pre-dates the current civil-status registration system in Saudi Arabia is a recurring source of friction.

What is not sufficient

A statement from the applicant’s personal accountant on their letterhead is not accepted by any of the major DD firms as standalone evidence. We have seen this rejected on every recent file where it was the primary submission.

A “source of wealth” affidavit signed by the applicant in front of a Saudi notary is also not standalone evidence. It is supporting documentation only.

Photocopies of older bank statements, without bank-issued certified copies covering the same period, are typically queried. Saudi banks vary in how quickly they can produce certified historical statements; SAB and Riyad Bank in our experience are responsive within two weeks, others slower.

The pack we now build before submission

Every Gulf-origin file we open now includes the following before we send it to the CIU. This adds 4-6 weeks at the front end of the engagement. It removes, in our experience, around 80% of the DD queries that would otherwise come back two months later.

1. ZATCA tax compliance certificate, dated within 90 days of submission.
2. Certified bank statements covering 36 months from the primary operating account.
3. Audited or third-party-reviewed financial statements of any entity in the wealth chain, covering the three years preceding the planned contribution.
4. A written source-of-wealth memorandum, drafted by us, signed by an independent Saudi-licensed lawyer who has reviewed the underlying documents. We do not draft the memorandum without independent legal review; the memorandum without that signature is not credible to the DD firms.
5. ID and proof-of-address documentation in current form, including UAE residency cards where the applicant holds one.

The pack costs roughly USD 4,000 to USD 8,000 in third-party document and review fees, depending on the complexity of the wealth chain. It is the cheapest insurance against a four-month calendar slip.

A note on entity restructurings

Several Saudi family offices have, since 2023, restructured their holding entities in response to Vision 2030 corporate-law changes. These restructurings are usually clean from a Saudi compliance perspective. From the DD firm’s perspective, they introduce a documentation discontinuity.

If your holding structure was restructured in 2023 or 2024 and you are filing a Caribbean CBI in 2026 or 2027, expect the DD firm to ask for documentation covering both the pre-restructure and post-restructure entities. Plan for this. The Saudi corporate-law office can produce certified pre-restructure incorporation documents on request, but the request needs to be in writing and with a 4-week lead time.

What this changes about our intake

We have moved our Saudi-origin intake to a two-stage process. Stage one is a four-week documentation sprint; stage two is the CIU file. We will not file the CIU file without the documentation pack at the front. Clients who push us to file faster end up with longer total elapsed time, because the documentation request comes back from the DD firm anyway and now arrives two months later instead of at the start.