About this programme

In February 2026 the Financial Action Task Force placed Kuwait on its list of jurisdictions under increased monitoring. The UK's list of high-risk third countries is aligned with the FATF's, and a listing engages the requirement to apply enhanced due diligence to business relationships and transactions involving a person established there (Money Laundering Regulations 2017, regulation 33). It lands on top of risks that generic screening tools already handle poorly: an extended ruling family and a political class holding public functions while the National Assembly has been suspended since 10 May 2024; a nationality system in which tens of thousands of people have had their citizenship withdrawn since 2024; and an economy with no personal income tax, where the usual evidence of source of wealth does not exist.

This is not an introduction to EDD. It is a two-hour, case-based workshop for practitioners who already run EDD and want to do it properly on Kuwait: who counts as a Kuwaiti PEP and how to map family and tribal connections; how to screen Arabic names across transliterations; what the nationality withdrawals mean for identity documents and ongoing monitoring; how to corroborate wealth from public-sector remuneration, commercial agencies, family business groups and real estate; how Kuwaiti corporate forms can obscure beneficial ownership; and where terrorist-financing designations of Kuwait-based fundraisers and charities still matter.

Participants work through anonymised Kuwait-linked client profiles, including live screening demonstrations on Kuwait Mirror Intelligence, and document an EDD decision for each. Places are limited to 12, and every participant is expected to take part.

The workshop is professional training, not legal advice, and does not replace your firm's own risk assessment.

Course structure

Module 1 Why Kuwait, Why Now Kuwait's February 2026 FATF listing, what it triggers for UK firms under regulation 33 of the Money Laundering Regulations 2017, and how to evidence it in your risk assessment.
Module 2 Kuwaiti PEPs, Networks and Names The ruling family, the Amiri Diwan, ministers, the judiciary and state-owned entities; public functions with the National Assembly suspended; family members and close associates through tribal and marriage ties; screening Arabic names across transliterations without false negatives.
Module 3 Identity After the Nationality Withdrawals How the withdrawals since 2024 affect Kuwaiti passports and civil ID cards, what to do when a customer's nationality has changed, and trigger events for ongoing monitoring.
Module 4 Source of Wealth and Beneficial Ownership Corroborating wealth where there is no personal income tax; Kuwaiti company forms under the Companies Law (Law No. 1 of 2016), foreign-ownership rules and nominee arrangements; the red flags in each.
Module 5 Sanctions Exposure and Live Casework Past UN, US and UK designations of Kuwait-based fundraisers and charities; then anonymised profiles screened live and a documented EDD decision for each.

Learning outcomes

By the end, participants will be able to:

Explain what Kuwait's FATF listing requires of a UK regulated firm and record it in your risk assessment
Identify Kuwaiti PEPs, family members and close associates beyond what commercial lists show
Screen Kuwaiti names reliably across Arabic transliterations
Verify identity and monitor customers affected by the nationality withdrawals
Corroborate source of wealth and beneficial ownership for Kuwait-connected customers without tax records
Document a defensible EDD decision on a Kuwait-linked profile

Who should attend

MLROs and deputy MLROs
EDD, KYC and onboarding team leads
Financial crime investigators and analysts
Compliance professionals in banking, wealth management, law, accountancy and property

Prerequisites

At least three years in financial crime compliance and a working knowledge of the Money Laundering Regulations 2017 and the risk-based approach. The workshop does not cover EDD basics.

Subject areas

Political RiskFinancial Crime Compliance (EDD, AML/CFT, Sanctions)