SAMA emphasizes the importance of the financial sectors operating in the Kingdom within the scope of their supervision to comply with the AML/CFT instructions communicated by SAMA and the standards issued by the relevant international organizations - the Financial Action Task Force (FATF) and the Basel Committee (BIS) - regarding the correct application of the risk-based approach (RBA), which is based in one aspect on financial institutions conducting a study and assessment of the risks resulting from dealing with individuals, natural and legal persons, states and various entities in a way that ensures the provision of all financial services to all segments of society.

When implementing precautionary measures in its dealings with certain countries, entities, and individuals classified as high-risk—such as those associated with countries subject to economic sanctions, those failing to comply with international standards, or those that do not fully or adequately implement such standards—it is necessary to conduct prior studies and assess the risks on a case-by-case basis. Decisions should be made individually in cases where the information provided by the client is insufficient. A blanket prohibition on financial dealings or the collective termination of financial relationships should be avoided, as this may deprive segments of society of access to financial services through licensed channels.

SAMA cautions against the misconceptions surrounding the concept of "De-risking," particularly the notion that it inherently fulfills anti-money laundering (AML) or counter-terrorism financing (CTF) requirements. De-risking should not be understood as financial institutions terminating, restricting, or avoiding business relationships with entire categories of clients solely due to the limited financial returns derived from dealing with them compared to the increased costs of enhanced monitoring and oversight. Nor should it be viewed as a means to avoid reputational risks associated with engaging with such categories.

Based on the above, appropriate measures for combating money laundering and terrorist financing must be implemented to achieve the goal of financial inclusion, ensuring that all members of society have access to affordable and accessible financial services. These measures should facilitate access for vulnerable and underserved groups, including those with limited income and residents of remote areas, rather than forcing them to turn to unregulated channels where tracking financial transactions becomes more challenging, thereby undermining the effectiveness of anti-money laundering and counter-terrorism financing efforts.

An analytical study and periodic reassessment of procedures must be conducted continuously to evaluate the financial transaction risks associated with countries, entities, and individuals. This ensures a balance between continuing to provide financial services to those who need them and maintaining full compliance with relevant local and international standards and requirements for combating money laundering and terrorist financing.