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The CMA opened consultation on 27 September 2026 for draft rules on capital-market institutions dealing with clients in financial markets outside Saudi Arabia. Comments are due by 27 October; the proposed date for final provisions to take effect is 1 November 2026. These are draft timetable details and should not be presented as current rules before adoption. The stated aim is to strengthen supervision of Saudi institutions’ activities in overseas markets.
Under the draft, where an external market is equivalent to the Main Market or the listed debt-instruments market, an institution would have to satisfy suitability requirements before it begins dealing with a client there. It would not have to repeat the assessment before every subsequent transaction unless a material change in the client’s information or circumstances warrants a review. The proposal therefore specifies when suitability checks should occur while retaining a trigger to revisit them when client circumstances change.
For margin transactions involving securities in external markets, the draft would require clients to provide margin of at least 50% of transaction value and require periodic monitoring of that margin. It would prohibit this type of trade in highly leveraged instruments or in companies whose accumulated losses exceed half of their capital. These are proposed safeguards; the source does not report that any existing client has a margin shortfall or suffered a loss. The controls are aimed at screening product and company risks in advance.
Conditionally, a higher initial margin could reduce credit exposure for clients and intermediaries during sharp price moves, while also increasing capital needs and limiting access to leveraged trades. The frequency of suitability checks would have to balance avoidable transaction delay against relying on a client profile that has become outdated. The net effect depends on the final scope and supervision. CMA said it would consider public feedback before approving the final text. As of 8 October, the 50% margin and 1 November date remained draft proposals, not adopted obligations.
The proposal also places the client’s margin burden and the intermediary’s oversight duty within one risk framework. How implementation would fit custody and pricing practices across different overseas markets will matter for understanding the final text.


