ARTICLES & UPDATES

– Written warning
– Order requiring compliance with specified corrective measures
– Financial fine of KWD 200
– Written warning
– Order requiring compliance with specified corrective measures
– Financial fine of KWD 200
– Written warning
– Order requiring compliance with specified corrective measures
– Financial fine of KWD 500
– Written warning
– Order requiring compliance with specified corrective measures
– Financial fine of KWD 200

Second: Medium-Risk Violations

Administrative penalties, financial penalties, or both may be imposed. Financial fines increase progressively in the event of repeated violations, provided that the total fine for a single violation shall not exceed KWD 500,000, as follows:

Violation

Conducting sales and purchase transactions using cash.

Failure to appoint a Kuwaiti Compliance Officer knowledgeable in the Anti-Money Laundering and Counter-Terrorism.

Financing Law and related ministerial resolutions.

Failure to implement due diligence procedures.

Failure to retain financial records for a period of five years.

Applicable Measures and Penalties

– Financial fine of KWD 3,000
– Closure of the establishment and referral to the competent investigation authorities
– Revocation of the commercial license
– Order requiring compliance with specific corrective measures
– In case of repetition: financial fine of KWD 500
– Suspension of the commercial license until the violation is rectified
– Order requiring compliance with specific corrective measures
– In case of repetition: financial fine of KWD 500
– Suspension of the commercial license for three months
– Revocation of the commercial license
– Financial fine of KWD 1,000
– Suspension of the commercial license for three months
– Revocation of the commercial license

Additional Medium-Risk Violations:

Violation

Failure to establish AML/CFT policies, procedures, systems, and controls and circulate them to local and foreign branches.

Failure to submit the establishment’s risk assessment study.

Failure to implement an electronic system to record all customer data and transactions as required by the Ministry of Commerce and Industry.

Failure to identify the beneficial owner and maintain records of beneficial ownership and ownership structure in commercial transactions.

Applicable Measures and Penalties

– Financial fine of KWD 500
– Suspension of the commercial license for three months
– Revocation of the commercial license
– Financial fine of KWD 500
– Suspension of the commercial license for three months
– Revocation of the commercial license
– Financial fine of KWD 500
– Suspension of the commercial license until the violation is rectified
– Financial fine of KWD 500
– Suspension of the commercial license for three months
– Revocation of the commercial license

Third: High-Risk Violations

Administrative penalties, financial penalties, or both may be imposed. Financial fines increase progressively in the event of repeated violations, provided that the total fine for a single violation shall not exceed KWD 500,000, as follows:

Violation

Failure to implement enhanced due diligence measures.

Failure to register or establish a mechanism for accessing local and international sanctions lists relating to terrorism financing and proliferation financing.

Failure to notify the Committee for the Implementation of United Nations Security Council Resolutions at the Ministry of Foreign Affairs within three working days when refusing to provide services to a client due to their inclusion in local or international sanctions lists relating to terrorism financing and proliferation financing.

Providing services to persons listed on local or international sanctions lists related to terrorism financing and proliferation financing.

Failure to notify the Kuwait Financial Intelligence Unit when suspicious transaction indicators exist within two working days.

Applicable Measures and Penalties

– Financial fine of KWD 4,000
– Suspension of the company’s activities for six months
– Revocation of the commercial license
– Financial fine of KWD 4,000
– Suspension of the company’s activities for six months
– Revocation of the commercial license
– Financial fine of KWD 4,000
– Suspension of the company’s activities for six months
– Revocation of the commercial license
– Financial fine of KWD 8,000
– Suspension of the company’s activities for one year
– Revocation of the commercial license
– Financial fine of KWD 5,000
– Suspension of the company’s activities for one year
– Revocation of the commercial license

Our Firm’s Advisory

Given the enhanced regulatory oversight and the introduction of the violations matrix, businesses should proactively review their AML/CFT compliance frameworks to ensure full alignment with the new requirements. Our firm regularly advises clients on a range of matters, including the development and implementation of AML/CFT compliance frameworks, conducting risk assessments and drafting policies, managing regulatory investigations and enforcement matters, as well as performing comprehensive corporate compliance reviews. If you require assistance in reviewing your compliance framework or understanding the implications of Ministerial Resolution No. 25 of 2026, please do not hesitate to contact us.