• 🇰🇼 Kuwait
  • CMA
  • Banking Regulations
  • Beneficial ownership

Kuwait Beneficial Ownership: CMA Circular 14/2026

Ultimate owner

In short: On 26 August 2026 Kuwait’s Capital Markets Authority issued Circular No. (14) of 2026, attaching an updated Supervisory Guidance on Beneficial Ownership that applies from that date. It sets a three-step test starting at 25%, adds waqf and change-reporting rules, and records a KD 1,000 to 10,000 fine for intentionally false data.

25% or moreStep 1 ownership or voting-rights test (para 41)
3 stepsOwnership, then other control, then senior managing official (para 40)
5 yearsMinimum record keeping after the relationship ends (para 77)
KD 1,000 to 10,000MOCI fine for intentionally false data (para 94)

Key facts

Authority Capital Markets Authority (CMA), Kuwait. The Ministry of Commerce and Industry (MOCI) runs the beneficial ownership register and the reporting route
Instrument CMA Circular No. (14) of 2026 Regarding the Update of the Supervisory Guidance on Beneficial Ownership, with the Supervisory Guidance on Beneficial Ownership (August 2026)
Issue date 26 August 2026 (circular page and signature line)
Effective date The date of issuance of the circular, 26 August 2026
Applies to Persons licensed by the CMA (the circular is addressed to them); the guidance is written for financial institutions and DNFBPs
Status In force since 26 August 2026. The circular sets no separate deadline
Official source https://www.cma.gov.kw/en/web/cma/cma-board-releases/resolutions-and-regulations/-/cmaboardreleases/detail/1986119
Last verified 13 October 2026, against the CMA circular page, the English guidance PDF, MOCI Circular No. (9) of 2026 and the IRU publications page

What did the CMA change?

The circular goes to all licensed persons and attaches the updated guidance, which applies from the date of the circular. The CMA says it will monitor compliance.

The circular names two main changes:

  • Changes in beneficial owner

    New procedures for when a supervised entity detects a change in the beneficial owner of a legal entity or arrangement, including reporting it to MOCI through the notification mechanism on MOCI’s system.

  • Waqf

    Amended and added items on the waqf and its beneficial owner, with an example of a waqf of real estate owned 100% by a natural person.

What does the guidance require?

Financial institutions and DNFBPs should follow a three-step approach to identify and verify the beneficial owner of a customer (para 40).

  • Step 1: 25% or more

    Find any natural person who directly or indirectly owns 25% or more of the customer’s capital or voting rights (para 41). Holdings multiply through layers: owning 60% of a company that holds 49% of the customer gives 29.4% (60% × 49%), so that person qualifies (para 48).

  • Step 2: control by other means

    If Step 1 finds nobody, or there is doubt, find the natural person who exercises ultimate effective control through means other than ownership (para 52). Examples include the power to appoint or dismiss directors (para 57).

  • Step 3: senior managing official

    If Steps 1 and 2 fail, identify and verify the senior managing official and treat that person as the beneficial owner (para 59).

  • Complex structures

    These are customers with three or more layers between the customer and the beneficial owner, or fewer layers that are hard to verify, for example where a foreign company or trust is involved (para 60). Kuwait does not recognise nominee shareholders domestically, but foreign entities in a chain may use them, so keep tracing to a natural person (para 51).

  • Waqf

    The guidance says the waqf is the only type of legal arrangement that exists in Kuwait (para 23). It lists the waqif (founder), the nazir (manager), the beneficiaries and any other person with effective control as beneficial owners (para 28).

  • Records

    Keep customer due diligence records, including beneficial owner documents, for at least five years after the business relationship ends or after an occasional transaction (para 77).

How is incorrect data reported?

Section 4 of the guidance says individuals, legal persons and competent authorities (including the Central Bank of Kuwait, the CMA and the Insurance Regulatory Unit) can report incorrect data. The reporter uses the Commercial Register electronic portal, attaches any supporting documents, and authenticates through the Hawiyti application.

MOCI Circular No. (9) of 2026, dated 17 May 2026, gives the portal address as ereg.moci.gov.kw. MOCI may then ask for the data to be updated within a set period, impose a financial penalty and suspend the Commercial Register until the breach is fixed, or coordinate with supervisors.

Who is affected?

The circular is addressed to persons licensed by the CMA. The guidance names the Central Bank of Kuwait, the CMA, the Insurance Regulatory Unit and MOCI as authorities that enforce beneficial ownership compliance (para 89).

Insurers have their own circulars. IRU Circular No. (15) of 2026, issued 14 July 2026, set a 30 July 2026 deadline for documents. IRU Circular No. (18) of 2026, issued 2 September 2026, tells IRU-supervised companies to follow the updated beneficial ownership guide approved by the National AML/CFT Committee. This post did not search for a Central Bank circular.

What should firms do next?

The five points below are practical advice, not requirements of the circular:

  1. Rewrite the CDD procedure.Follow the three steps in order and record why you stopped.
  2. Add an aggregation sheet.Multiply holdings through every layer so indirect owners are not missed (para 49).
  3. Set escalation triggers.Send chains of three or more layers to enhanced review (para 60).
  4. Build the reporting route.Name who files portal reports and who notifies MOCI of changes.
  5. Train and keep evidence.Brief onboarding teams and keep records for at least five years.

Deadlines and penalties

The circular sets no deadline. It applies from 26 August 2026.

The CMA says non-compliance will subject a licensed person to the measures in Article (15) of Law No. 106 of 2013, without prejudice to the criminal penalties in that law. Supervisors can warn, require corrective action or fine, and in extreme cases suspend or revoke licences (para 90).

MOCI may impose a fine of not less than KD 1,000 and not more than KD 10,000 on any natural person who intentionally submits false or misleading beneficial owner data (para 94). Penalties follow a proportionality principle (para 95).

Frequently asked questions

What is the beneficial ownership threshold in Kuwait?

Step 1 of the guidance looks for a natural person who directly or indirectly owns 25% or more of the customer’s capital or voting rights (para 41). If nobody meets it, or there is doubt, the test moves to control through other means, then to the senior managing official (paras 52, 59).

How do I report incorrect beneficial ownership data in Kuwait?

Use the Commercial Register electronic portal, choose the reporting service, attach supporting documents and authenticate through the Hawiyti application (guidance, section 4). MOCI Circular No. (9) of 2026, dated 17 May 2026, gives the address ereg.moci.gov.kw.

What is the penalty for false beneficial ownership data?

The guidance says MOCI may impose a fine of not less than KD 1,000 and not more than KD 10,000 on any natural person who intentionally submits false or misleading data, applied with regard to proportionality (paras 94 to 95).

Does the CMA circular apply to banks?

The circular is addressed to persons licensed by the CMA. The guidance itself speaks to financial institutions and DNFBPs and names the Central Bank of Kuwait among the supervisors. This post did not check any Central Bank circular, so banks should confirm their own supervisor’s position.

Sources (official, verified 13 October 2026)

  1. CMA, Circular No. (14) of 2026 Regarding the Update of the Supervisory Guidance on Beneficial Ownership, 26 August 2026 https://www.cma.gov.kw/en/web/cma/cma-board-releases/resolutions-and-regulations/-/cmaboardreleases/detail/1986119
  2. CMA, Supervisory Guidance on Beneficial Ownership, August 2026 (English PDF) https://www.cma.gov.kw/documents/55799/0/%D8%A7%D9%84%D8%AF%D9%84%D9%8A%D9%84%20%D8%A7%D9%84%D8%A7%D8%B1%D8%B4%D8%A7%D8%AF%D9%8A%20%D9%84%D9%85%D9%81%D9%87%D9%88%D9%85%20%D8%A7%D9%84%D9%85%D8%B3%D8%AA%D9%81%D9%8A%D8%AF%20%D8%A7%D9%84%D9%81%D8%B9%D9%84%D9%8A%20-%20%D8%A8%D8%A7%D9%84%D9%84%D8%BA%D8%A9%20%D8%A7%D9%84%D8%A7%D9%86%D8%AC%D9%84%D9%8A%D8%B2%D9%8A%D8%A9.pdf/f80c399d-ced5-67a0-b6c5-46bcfe7771fa
  3. MOCI, Circular No. (9) of 2026 on reporting incorrect beneficial owner identity, 17 May 2026 (Arabic) https://www.moci.gov.kw/ar/important-links/taamym-rkm-9-lsn-2026-bshan-lblgh-aan-aadm-sh-hoy-lmstfyd-lfaaly/
  4. MOCI, Guidance on the Concept of the Beneficial Owner (Arabic) https://www.moci.gov.kw/ar/important-links/ldlyl-lrshdy-lmfhom-lmstfyd-lfaaly/
  5. IRU, Publications: Circular No. (15) of 2026 (14 July 2026) and Circular No. (18) of 2026 (2 September 2026), both in Arabic https://www.iru.gov.kw/Publications
  • Kuwait
  • CMA
  • MOCI
  • Beneficial ownership
  • AML/CFT
  • FATF Recommendations 24 and 25
  • Waqf

This post is information, not legal advice. Check the current official text before you act.

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