Al Rajhi Bank

🔴 High Risk

Al Rajhi Bank, Saudi Arabia’s largest Islamic bank by capital, operates a vast network of over 500 branches across the Kingdom, with subsidiaries like Al Rajhi Bank Malaysia, Al Rajhi Bank Jordan, and Al Rajhi Bank Kuwait. Headquartered at Al Rajhi Bank head office Riyadh on King Fahd Road, the institution founded by Al Rajhi Bank founder Sulaiman bin Abdulaziz Al Rajhi in 1957 has grown into a Al Rajhi Bank net worth powerhouse, boasting Al Rajhi Bank revenue exceeding SAR 1 trillion in assets and a Al Rajhi Bank stock (Tadawul: 1120) market cap around SAR 300 billion as of 2025.

This case draws scrutiny in the global Anti–Money Laundering (AML) landscape due to repeated U.S. citations of Al Rajhi Bank Money laundering risks, including a 2003 CIA report labeling it a “conduit for extremist finance,” despite no sanctions, fines, or proven laundering schemes. Its significance lies in exemplifying how unadjudicated allegations sustain high Customer due diligence (CDD) and Know Your Customer (KYC) scrutiny for correspondent banking ties, influencing Financial Transparency standards worldwide.

Background and Context

Al Rajhi Bank history traces to 1957 as a money exchange by the Al Rajhi brothers, converting to a joint stock company in 1988 and listing on Tadawul. Under Al Rajhi Bank CEO Saleh bin Abdullah Al Lheidan and Al Rajhi Bank board of directors led by Chairman Abdullah Sulaiman Al-Rajhi, it expanded via Al Rajhi Bank investment arms like Al Rajhi Capital and branches in Al Rajhi Bank Dammam, Al Rajhi Bank Jeddah, Al Rajhi Bank Jubail, and international outposts.

Pre-controversy growth reflected strong Corporate Governance, with Al Rajhi Bank annual report filings to SAMA and CMA emphasizing Sharia compliance. The timeline escalated post-9/11: 2002 U.S. searches of Virginia nonprofits linked to Al Rajhi family boards; 2003 CIA assessment alleging family support for extremists; media reports on “Golden Chain” al Qaeda funders including Al Rajhi names.

No Suspicious transaction reports tied directly to the bank, but these fueled Name screening flags, marking the shift from regional giant to global AML watchlist staple.

Mechanisms and Laundering Channels

No court-proven Money Laundering at Al Rajhi Bank, but U.S. reports spotlighted potential channels. The CIA claimed Al Rajhi Bank couriers funded Indonesian insurgents in 2000, suggesting Electronic funds transfer (EFT) misuse. Senate HSBC reports criticized unmonitored “nested” flows via Al Rajhi Bank Malaysia and Jordan affiliates, risking Trade-based laundering or Structuring in high-volume correspondent banking.

Allegations referenced Shell company ties via U.S.-raided Safa Group (Al Rajhi family on initial board), accused of “layering” for terrorists, though subpoenas cleared direct bank involvement. No Offshore entity or Al Rajhi Bank Offshore entity evidence emerged; structures like 100% subsidiaries (e.g., Al Rajhi Bank Berhad in Malaysia) appear legitimate. Beneficial Ownership centered on Al Rajhi family (~2% direct shares), raising Al Rajhi Bank Beneficial owner and Al Rajhi Bank Politically exposed person (PEP) queries due to historical influence, but no Linked transactions confirmed illicit flows.

U.S. probes dominated: Post-9/11 lawsuits under Anti-Terrorism Act alleged Al Rajhi Bank Fraud via charity transfers to al Qaeda-linked groups; all dismissed by 2005 (Southern District of New York) and upheld by Supreme Court in 2014 for lacking proof of knowing aid. NY DFS 2017 fined another bank $630M partly for lax Al Rajhi Bank controls, citing Congressional scrutiny without penalizing Al Rajhi Bank itself.

No OFAC sanctions or SAMA actions; Al Rajhi Bank denied claims in 2012 letters, settling a WSJ defamation suit without admission. This aligns with FATF Recommendation 10 on CDD for high-risk corridors, highlighting gaps in Al Rajhi Bank KYC for terror-prone jurisdictions, though no FATF gray-listing followed.

Financial Transparency and Global Accountability

The case exposed Financial Transparency fissures in Saudi-U.S. banking links. HSBC’s continued Al Rajhi Bank ties post-2005 de-risking alerts (ignored by Middle East arms) underscored weak cross-border name screening. Watchdogs like Senate Subcommittee faulted absent Beneficial Ownership disclosures on nested activity.

Internationally, it spurred enhanced AML due diligence: European/U.S. banks imposed Al Rajhi Bank transaction caps. No direct reforms traced solely here, but it bolstered FATF calls for correspondent banking data sharing, influencing post-2012 global standards amid Saudi’s high-risk rating.

Economic and Reputational Impact

Al Rajhi Bank stock dipped temporarily post-Senate report, but rebounded; Al Rajhi Bank valuation hit record highs by 2025, with Al Rajhi Bank financial statements showing robust Al Rajhi Bank revenue. Partnerships strained—HSBC severed some ties—yet Al Rajhi Bank business expanded, including Al Rajhi Bank gold and Al Rajhi Bank products like murabaha financing.

Reputational hits persisted: Al Rajhi Bank careers and Al Rajhi Bank jobs face stigma in Western markets, eroding trust despite no Forced liquidation. Broader effects rippled to MENA stability, deterring investors wary of Cash-intensive business proxies.

Governance and Compliance Lessons

Al Rajhi Bank board of directors (11 members, Sharia oversight) affirmed Corporate Governance via 2023 reports, but U.S. critiques implied lapses in internal controls for Al Rajhi Bank group flows. Post-allegations, Al Rajhi Bank bolstered AML/CTF programs per its 2025 policy, emphasizing risk-based monitoring.

Lessons include rigorous Al Rajhi Bank CDD for family-linked entities and tech-driven KYC; regulators pushed SAMA for stricter Hybrid money laundering detection, closing gaps in Al Rajhi Bank statement audits.

Legacy and Industry Implications

Al Rajhi Bank’s saga shaped AML enforcement, becoming a benchmark for “reputational risk” in Islamic finance. It catalyzed de-risking of Saudi corridors, influencing Al Rajhi Bank Dubai expansions under heightened scrutiny. No turning point like HSBC’s $1.9B fine, but it embedded Al Rajhi Bank Shell company probes in routine compliance.

Industry-wide, it advanced FATF peer reviews for MENA, elevating Transparency in Al Rajhi Bank investment vehicles and Al Rajhi Bank locations like Al Rajhi Bank Qatif or Yanbu.

Al Rajhi Bank exemplifies persistent Al Rajhi Bank Suspicious transaction shadows from unproven terror links, dismissed suits, and risk citations without penalties. Core lessons stress vigilant Anti–Money Laundering (AML), robust Beneficial Ownership tracing, and cross-border Financial Transparency to shield global finance from conduit risks.

Country of Incorporation

Saudi Arabia

Headquarters in Riyadh, Saudi Arabia (Al Rajhi Bank Tower, 8467 King Fahd Road); operates primarily in Saudi Arabia with over 500 branches, plus subsidiaries and branches in Kuwait (Al Rajhi Bank – Kuwait, 100%), Jordan (Al Rajhi Bank-Jordan, 100%), Malaysia (Al Rajhi Corp – Malaysia, 100%), and holdings in Syria; total assets exceed SAR 1,039 billion with ~24,000 employees

Banking (world’s largest Islamic bank by capital; offers retail, corporate, investment banking, brokerage via Al Rajhi Capital, insurance holdings, and Sharia-compliant services)

Publicly listed joint stock company on Tadawul (Saudi Arabian Stock Exchange, ticker: 1120) since 1988; ~75% publicly owned with Al Rajhi family as largest shareholders (e.g., Abdullah bin Sulaiman Al Rajhi at ~2.179%); extensive subsidiary network including 100% ownership of Al Rajhi Capital, Emkan Finance, Tawtheeq Co., New Technology Software Solutions, International Digital Solutions, Management and Development for Human Resources, Tuder Real Estate, and partial stakes like 35% in Al-Rajhi Company for Cooperative Insurance and 90% in Ejada Systems; governed by Board of Directors (11 members, mix of executive/non-executive/independent), Shariah Board, and committees per SAMA and CMA regulations

No proven mechanisms; alleged historical risks in correspondent banking (e.g., unmonitored nested activity via affiliates in Malaysia/Jordan), high-volume flows flagged for potential terrorist financing conduits, but claims dismissed in court; treated as high-risk for trade-based or layering risks in AML contexts due to past U.S. scrutiny, though no direct evidence of bank-led schemes

Al Rajhi family dominates (Abdullah bin Sulaiman Abdul Aziz Al Rajhi, ~2.179% shares; other minor holders like Mansour Abdulaziz Rashid Albosaily 0.0042%); Board includes Chairman Abdullah Sulaiman Al-Rajhi, Saleh bin Abdullah Al Lheidan (CEO, holds shares), Abdulaziz bin Hameen Al-Hameen, Sulaiman Al-Majed; no direct PEP links publicly tied to laundering, but family historically influential in Saudi business

No (family members politically exposed historically via Saudi business ties, but no confirmed PEP designation in laundering contexts; bank denies any illicit involvement)

No direct appearances in Panama Papers, FinCEN Files, or Pandora Papers; repeatedly cited in U.S. Congressional reports (e.g., Senate HSBC AML report, 9/11 Commission-related), CIA assessments, and CRS reports on Saudi terrorist financing; civil suits by 9/11 victims; no leaks confirming laundering

High (Saudi Arabia rated high-risk for terrorist financing by U.S. agencies; bank’s correspondent ties amplify scrutiny despite no sanctions)

No U.S. sanctions (OFAC), fines, or blacklisting against the bank; multiple U.S. civil suits (e.g., O’Neill v. Al Rajhi Bank, Bernhardt v. Iran-related) under Anti-Terrorism Act dismissed with prejudice by courts including U.S. Supreme Court (2014) for failure to prove knowing aid to specific acts; NY DFS 2017 action against other banks cited Al Rajhi as high-risk example without penalizing it; no Saudi SAMA fines for AML; bank issued 2012 denial letter post-Senate report

Active (publicly traded, expanding; no dissolution or sanctions as of 2025)

  • 1957: Founded as private entity by Al Rajhi brothers

  • 1987-1988: Converts to joint stock company, lists on Tadawul

  • Mid-1990s: CIA alleges extremists use bank as conduit (classified report later publicized)

  • 2003: CIA assessment “Al Rajhi Bank: Conduit for Extremist Finance” claims family ties to extremists

  • 2006: Rebrands to Al Rajhi Bank; expands to Malaysia

  • Post-9/11 (2001-2014): Multiple U.S. civil suits by victims alleging Al Qaeda funding facilitation; all dismissed (Supreme Court upholds 2014)

  • 2012: Senate HSBC report flags Al Rajhi relationship as high-risk; bank responds denying terror links

  • 2017: NY DFS fines other bank $630M partly for weak Al Rajhi controls

  • 2023: Publishes governance report affirming SAMA/CMA compliance

  • 2025: Market cap ~SR 302.80B; ongoing operations

Correspondent Banking Risks, Potential Conduit

MENA, Saudi Arabia

High Risk Jurisdiction, Terrorism Financing

Al Rajhi Bank

Al Rajhi Bank
Country of Registration:
Saudi Arabia
Headquarters:
Riyadh, Saudi Arabia (Al Rajhi Bank Tower, King Fahd Road) ​
Jurisdiction Risk:
High
Industry/Sector:
Banking / Islamic Banking ​
Laundering Method Used:

No proven methods; alleged risks in correspondent banking (nested activity via Malaysia/Jordan affiliates), potential terrorist financing conduit 

Linked Individuals:

Al Rajhi family (Abdullah bin Sulaiman Al Rajhi ~2.179% shares, Chairman Abdullah Sulaiman Al-Rajhi); CEO Saleh bin Abdullah Al Lheidan; no proven illicit links 

Known Shell Companies:

N/A

Offshore Links:
Estimated Amount Laundered:
N/A
🔴 High Risk