Entering the Saudi Stock Market as a Foreign Investor 2026

GCC Public Equities Investment Screening Report - Saudi Arabia

Foreign investor entry, USD 1 million to USD 10 million mandate, three-to-five-year horizon, as specified in the commission

Saudi public-equity access has materially improved, but legal eligibility does not establish an economical, executable entry framework. The unresolved condition is a documented account-cost and stressed-liquidity assessment, scheduled for reassessment on 20/11/2026, not an assumption that further ownership liberalisation will generate returns. REPORTED[1] ESTIMATED

Executive Summary

SECTOR VIEW: SELECTIVE, because the access reform is established but applicant-specific operating costs and stressed exit capacity remain unmeasured. WHY: Direct ownership no longer depends on the former institutional qualification framework, materially improving access for smaller foreign investors. However, headline capitalisation, index weights and executable liquidity are different measures, while fixed account costs can erase the apparent advantage of direct ownership at the smaller ticket. No specific target named in the brief. Conviction-level commitment requires a named target. This report is a sector screen, not a deal verdict. WHAT WOULD CHANGE THIS: A documented assessment by 20/11/2026 demonstrating applicant acceptance, competitive all-in costs and security-level stressed exit capacity would establish whether a practical entry framework clears the screen. Confidence: MEDIUM (53%), because the subject is an unnamed sector screen and the material commercial and liquidity evidence is predominantly reported or estimated rather than verified primary documentation.

Investment Thesis

The investable thesis is improved access to Saudi corporate earnings, not guaranteed appreciation from opening the market. The CMA announced broader foreign access on 06/01/2026, effective 01/02/2026, removing the Qualified Foreign Investor framework and the previous swap-agreement access framework. The resulting direct route is a material improvement for foreign natural persons and legal entities. REPORTED[1] [2]

The screen favours a comparison between direct ownership through a Saudi intermediary, international brokerage connectivity and a regulated pooled structure. It does not presume that one route dominates across the mandate. Direct ownership offers control over security selection and ownership-headroom management; a pooled structure can spread fixed administration costs but introduces manager fees, mandate constraints and redemption terms. LEGAL ESTIMATED

SNB Capital and Interactive Brokers provide a named example of international brokerage connectivity. Their public partnership establishes an access proposition, not confirmation that every domicile, legal form or account is eligible under identical terms. Written acceptance, custody documentation and fee schedules remain necessary. REPORTED[3] [4]

Exit depends on secondary-market trading capacity followed by settlement, conversion and outbound remittance. There is no assumed acquisition exit, guaranteed redemption or valuation uplift from reform. The strategy must remain defensible if ownership ceilings never increase and incremental index flows disappoint.

Mandate answered: a credible legal access route exists, but an executable, costed implementation package satisfying the mandate has not been established. No named target is assessed. A named opportunity would need separate diligence.

Capital Structure

Not applicable, sector screen.

There is no operating-company financing round, post-money valuation or preference stack to assess. The relevant capital-structure diligence concerns the ownership chain, client-asset segregation, intermediary insolvency treatment and, for a pooled structure, unit classes and redemption rights. LEGAL

Macro Assessment

Saudi public-equity exposure is not equivalent to exposure solely to oil production. Banks, telecommunications, materials, utilities and domestic-demand businesses transmit different earnings drivers, but fiscal spending, domestic credit conditions and state-linked capital allocation can connect them economically. Sector diversification alone therefore does not establish independence from the sovereign investment cycle. ESTIMATED

The Public Investment Fund, PIF, must be assessed through its dual portfolio-return and domestic-development mandate, not treated as an unconditional source of support for minority shareholders. Its role in the analysis is as a strategic shareholder and capital allocator whose objectives can affect corporate investment, ownership supply and distribution policy. Current portfolio exposure to common state-linked decision makers requires a separate ownership map. REPORTED[5]

For a GCC sovereign-wealth or family-office portfolio, the appropriate role would be assessed against existing Saudi fiscal, banking, property and private-market exposure. An additional Saudi public-equity mandate may increase concentration rather than diversify it, even if its legal vehicle is offshore. No sovereign allocation or policy-support assumption is embedded in this screen. ESTIMATED

The reported ownership-limit review is optionality, not an earnings forecast. The available legal commentary describes a review but supplies no binding decision date or final increase. Passive index effects would depend on the adopted rules, issuer free float, index methodology and implementation schedules. No automatic inflow amount is included. REPORTED[6]

Sector Health

Access health: improved. Valuation attractiveness: not established. Liquidity breadth: requires measurement.

The market correction is evidence against treating reform as sufficient investment justification. For the reporting year ending 31/12/2025, Argaam reported a TASI decline of approximately 12.84% and a decline in traded value of approximately 30.24%, citing Saudi Exchange statistics. These are historical observations, not current valuation or execution inputs. REPORTED[7]

TASI is the Tadawul All Share Index. Headline listed-company capitalisation, free-float-adjusted index capitalisation and daily turnover are not interchangeable. Likewise, MSCI Saudi Arabia weights cannot be relabelled as TASI weights. REPORTED[8] [9]

No qualifying listed REIT meets the brief's criteria on the evidence assembled. Reason: no vehicle-level distribution, leverage and stressed-liquidity assessment has been established. This is an evidence limitation, not a finding that Saudi REITs are universally unsuitable.

The MSCI Saudi Arabia Index and the iShares MSCI Saudi Arabia ETF appear only as concentration, cost and performance comparators. Neither is presented as a holding or allocation. REPORTED[9] [10]

Commercial Terms

PRICING MODEL: Direct access combines brokerage per transaction, custody or administration charges, settlement processing and FX conversion. Pooled access typically uses asset-based charges, potentially supplemented by other fees. No executable quotation has been established. ESTIMATED

GROSS MARGIN PER PRODUCT LINE: Not applicable to this public-equity entry screen. No broker or fund manager is being assessed as an acquisition target.

UNIT ECONOMICS: Investor account economics replace company CAC, LTV and payback. An annual minimum of USD 5,000 to USD 15,000 absorbs 0.5% to 1.5% of a USD 1 million account, versus 0.05% to 0.15% of a USD 10 million account, before other charges. ESTIMATED

REVENUE RECOGNITION PATTERN: Not applicable to a target company. For route comparison, transaction charges occur with dealing and processing, while recurring asset-based charges accrue over time. Exact treatment follows the service agreement. ESTIMATED

The commercial hurdle is all-in net performance after fixed charges, recurring fees, FX, withholding, market impact and operating cash drag. The lowest advertised brokerage commission does not establish the lowest-cost route.

Regulatory Position

Legal Opinion

Access and investor status. The reported amendments effective 01/02/2026 remove QFI qualification and the previous swap-agreement access framework for the Main Market. Entry is through an appropriately authorised intermediary, with account-opening, ownership and compliance requirements continuing to apply. Nomu eligibility is a separate question and is not inferred from Main Market access. LEGAL REPORTED[1] [11]

Ownership restrictions. The reported general rule prohibits a non-resident foreign investor from owning 10% or more of an issuer, while aggregate foreign ownership is generally capped at 49%, subject to applicable exclusions and stricter issuer or sector restrictions. These are issuer-level constraints, not an exchange-wide foreign-ownership ceiling. Affiliate aggregation, strategic-investor exclusions and bank-specific requirements need precise treatment in the compliance specification. LEGAL REPORTED[12]

Structuring options.

• Direct account: The screen favours testing this route first where segregated ownership and portfolio control justify the operating cost. The agreement must establish the investor's registered and beneficial rights, custody chain and insolvency treatment. LEGAL
• Regulated pooled vehicle: A legitimate comparison where administration is shared across investors. Distribution permissions, eligibility, mandate, fees, liquidity and custody require vehicle-specific assessment. LEGAL
• Foreign Strategic Investor route: Not an appropriate default for a liquid portfolio mandate. Its strategic purpose, ownership treatment and restrictions require separate legal analysis. It is not a workaround for ordinary portfolio limits. LEGAL REPORTED

Licensing evidence limitation. The available record contains provider service descriptions, but no current CMA register extract or licence number establishing the exact contracting entity and authorised activities for this applicant. No individual provider licence is certified in this report. A service announcement is not a regulatory-register confirmation. LEGAL

Custody and settlement. Edaa provides securities depository services and Muqassa provides clearing functions. The published equity settlement cycle is T+2, meaning trade date plus two applicable settlement business days. Broker prefunding, credit limits and cash cutoffs are separate contractual matters. No universal funding entitlement, settlement-fail rate or penalty schedule is asserted. LEGAL REPORTED[13] [14] [15]

Tax. Domestic dividend withholding for non-residents is generally 5%. Qualifying listed-security gains may benefit from exemption under the Saudi Income Tax Law, but investor status, transaction type and statutory conditions require confirmation. Treaty relief is not presumed, and issuer-level tax or zakat must not be duplicated mechanically as a shareholder-level charge. LEGAL REPORTED[16] [17]

AML, reporting and legal sign-off. The account file must establish legal existence, ownership and control, authorised signatories, source of funds, tax residence and applicable FATCA/CRS classifications. Enhanced diligence depends on the applicant and its counterparties, not simply its stated FATF compliance. Current CMA Investment Accounts Instructions and AML rules are the verification path. Sign-off from Saudi-qualified counsel, with home-jurisdiction advice where relevant, is required before action. LEGAL REPORTED[18] [19]

Cross-border access and sanctions perimeter

China access boundary. QFII or RQFII access vehicles and Stock Connect / Bond Connect channels are not Saudi Main Market access routes. No qualifying China access vehicle meets the brief's criteria. Reason: the mandate concerns Saudi public equities, not Chinese securities. Any later China allocation would require a separate channel, custody and eligibility assessment. LEGAL

Iran: High where a material nexus is identified; Prohibited where applicable restrictions bar the transaction. Review under OFAC Iran sanctions, including IRGC [SANCTIONED: IRGC (OFAC, UK)]-related restrictions, is separate from any reference to the JCPOA framework. The JCPOA is not evidence of current permission for an otherwise restricted transaction. No Saudi issuer is alleged here to have an Iranian sanctions exposure. LEGAL REPORTED[20]

Russia: High where restricted counterparties or activities are identified; Prohibited where applicable restrictions bar the transaction. The assessment must distinguish OFAC Russia restrictions, EU restrictive measures and UK OFSI requirements. SDN list screening and Sectoral sanctions review answer different questions; one cannot substitute for the other. No Russian counterparty or mechanism is proposed. LEGAL REPORTED[20] [21] [22]

Ownership and control. OFAC's aggregate 50% ownership rule can block an entity not separately listed. It must not be applied backwards to conclude that every parent of a sanctioned subsidiary is automatically blocked. UK and EU ownership-and-control analysis can differ, and mere commercial contact with a sanctioned jurisdiction does not automatically make all passive shareholdings unlawful. LEGAL REPORTED[23]

Overall compliance posture: Medium pending applicant and counterparty screening. Low applies only after documented clearance of the relevant facts. High requires specialist escalation. Prohibited transactions are excluded, including attempts to disguise them through nominees, derivatives or intermediary jurisdictions. No completed sanctions clean bill is issued. LEGAL

Location Fit

Saudi Arabia is the securities-market jurisdiction. The investor's domicile governs separate questions of legal capacity, tax, distribution and reporting. A DIFC or ADGM vehicle does not, by its incorporation alone, establish Saudi eligibility, treaty entitlement or a securities-services permission. LEGAL

DIFC and ADGM can be considered as structuring jurisdictions only where there is a genuine governance or operating rationale. Relevant regulated activities require analysis under the DFSA or FSRA framework respectively; Saudi dealing and custody arrangements remain subject to the Saudi perimeter. LEGAL REPORTED[24] [25]

No qualifying DIFC or ADGM wrapper meets the brief's criteria on the evidence assembled. Reason: investor domicile, beneficial ownership, management location and binding wrapper-cost proposals have not been established. A new entity is therefore not presumed necessary or cost-effective.

Operational location matters through document certification, bank calendars, account cutoffs and service coverage. A physical visit or Saudi bank account requirement must be established from the selected provider's applicant-specific terms, not inferred from another customer's experience. LEGAL

Risk Matrix

Probabilities below are qualitative screening judgments, not measured frequencies. ESTIMATED

Critical Review

Exactly three killer questions

• What does the complete account cost for this applicant? Missing: a tax-inclusive quotation covering minimums, custody, dealing, processing, FX and remittance. Without it, the claim that direct access is economically superior collapses.

• What can the intended portfolio liquidate when turnover contracts? Missing: current security-level trading records, executable depth and proposed position sizes. Without them, “liquid public equities” can conceal an exit timetable inconsistent with the mandate.

• Does the expected return still clear the hurdle without further reform? Missing: an earnings, valuation and net-distribution model excluding ownership-cap relaxation. An unfavourable answer turns the thesis into a policy-event trade rather than a disciplined corporate-earnings exposure.

Exactly three fragile assumptions

• A legally open market is an operationally open account. Marketing encourages this shortcut. If wrong, domicile restrictions, documentation or prefunding terms determine access instead.

• A low foreign-ownership ratio predicts future demand. It can look like obvious headroom, but total-capitalisation denominators, strategic holdings and investor preferences complicate the inference. If wrong, the anticipated marginal buyer never appears.

• Different sector labels provide independent economic exposures. Shared fiscal, funding and ownership dependencies can invalidate that assumption. If wrong, the portfolio diversifies names without diversifying its principal loss drivers.

Exactly three inconvenient facts

• Historical reform narratives did not prevent market losses. The reporting year ending 31/12/2025 combined a TASI decline of approximately 12.84% with materially lower turnover. Access improvement alone therefore cannot justify an expected-return claim. REPORTED[7]

• Gross dividend yield is not cash received. At an illustrative 4% gross yield, 5% withholding reduces yield to 3.8%, before fees and home-country taxes. This is a 0.2 percentage-point return drag, not a five-percentage-point loss. REPORTED[16] ESTIMATED

• No complete executable portfolio has been established. The evidence does not include applicant acceptance, binding account economics and a current position-level liquidity study together. Describing entry as implementation-ready would outrun the available evidence.

Counterparty Moves

Part A: Competitor and Access-Provider Matrix

These are competing access propositions, not corporate acquisition targets. “OPERATING” refers to reported service activity, not independent certification of a current licence or applicant eligibility.

Part B: Recent Moves

1. The CMA converted foreign Main Market access from qualification-led entry to broader direct participation.

The announcement dated 06/01/2026 and effective date of 01/02/2026 are the decisive regulatory development. Legal commentary describes removal of the QFI framework and the previous swap-agreement framework, allowing broader direct participation through authorised intermediaries. REPORTED[1] [2] The commercial implication is narrower than an automatic positive market verdict: the investor can now test a direct account without treating the former qualification threshold as the governing obstacle. Ownership restrictions, account eligibility, tax and settlement remain separate. The condition is therefore an applicant-specific acceptance and operating package, not a renewed QFI application. This development supports an opening access window, but it does not supply a valuation discount or an execution budget. LEGAL

2. SNB Capital expanded its foreign-market-access proposition following the access reform.

SNB Capital's published Market Access Services announcement describes an institutional access offering directed at foreign financial counterparties. The exact release day is not established in the cited record, so none is assigned here. REPORTED[26] Its established Interactive Brokers partnership is relevant background, but its launch predates the recent-moves window and is not presented as a new event. REPORTED[3] The significance is competitive: standalone institutional custody proposals now need to demonstrate advantages over brokerage connectivity in service, control, total cost or permitted account structures. It remains unsupported to say that every foreign applicant needs only a permission toggle or receives identical custody treatment. The diligence requirement is a legal-entity-specific explanation of ownership registration, local intermediary roles, settlement funding and cash withdrawal. LEGAL

3. Investcorp and SNB Capital announced a strategic partnership, but it is not evidence of committed public-equity inflows.

The partnership announcement dated 08/02/2026 covers cooperation across asset management, investment banking, and wealth management, spanning Private Equity and Real Assets in Saudi Arabia and internationally. VERIFIED[29] It demonstrates institutional relationship-building around Saudi investment infrastructure. It does not establish that capital has been committed to Tadawul secondary-market equities, that direct accounts outperform pooled products, or that the mandate will receive institutional pricing. Those are separate claims requiring separate evidence. The timing implication is increasing competition among providers for foreign relationships. The practical condition is a competitive request for proposals rather than acceptance of a provider's scale or partnership pedigree as proof of value. Mandate scope, account service standards and net cost remain the relevant comparison points. ESTIMATED

4. The CMA's Simplified Investment Fund framework created an additional structuring option, not a universal shortcut.

Legal commentary identifies Instructions on Simplified Investment Funds under Board Resolution No. 1-26-2026 dated 02/03/2026. The reported framework provides a more flexible institutional private-fund structure. REPORTED[30] [31] Its existence does not establish applicant eligibility, launch economics or suitability for this liquid-equity mandate. Institutional classification, manager permissions, custody arrangements and contractual liquidity require Saudi counsel's assessment. The commercial implication is a broader wrapper comparison where pooling investors has a genuine purpose. For a standalone portfolio, establishment and governance costs may outweigh that flexibility. No cost saving, launch date or custody exemption is assumed for the principal. LEGAL ESTIMATED

5. MSCI's accessibility assessment separates improved investor qualification from residual market-operating constraints.

The MSCI 2026 Global Market Accessibility Review and country-comparison material identify continuing accessibility considerations alongside the improvement in investor qualification. Detailed assertions about omnibus accounts, nominee treatment or universal restrictions on securities lending are not treated here as conclusively established operating rules. REPORTED[32] The key implication is that broad legal access and institutional operational equivalence are different standards. The investor's service agreement must show how beneficial ownership, trade affirmation, failed settlement and corporate actions are handled in its actual chain. This evidence supports testing the complete account process before considering it implementation-ready. It does not prove that constrained hedge-fund participation reduces competition or creates an exploitable advantage for long-only investors. LEGAL

Part C: Intelligence Verdict

OPENING for access, not proven for returns: the principal's next action within the proposed ninety-day diligence window is to obtain and compare applicant-specific access, custody and execution packages, rather than anticipate an unannounced ownership-cap decision. ESTIMATED

Financial Frame

Route economics and return hurdle

The capital framework is an account-versus-wrapper decision followed by security-level underwriting. No unsupported expected-return forecast is assigned. A position would need to exceed the principal's approved net-return hurdle after all operating costs, taxes and implementation shortfall; that hurdle has not been supplied.

These are underwriting requirements, not factual forecasts. ESTIMATED

The published currency reference is SAR 3.75 per USD. A reference rate is not a guaranteed executable conversion price or a guarantee against future policy change. REPORTED[33]

Corrected execution arithmetic

For an illustrative USD 5 million position, equivalent to SAR 18.75 million using that reference rate, days to exit equal position value divided by permitted daily participation and observed daily traded value, rounded upward. This example is not a proposed position size. ESTIMATED

ESTIMATED

A provisional screen would limit each position to the smaller of 5% of portfolio value and the amount executable over ten sessions at 15% participation after a 70% turnover reduction. These limits are proposed controls, not estimates of guaranteed market capacity. ESTIMATED

Counterfactual

If ownership caps remain unchanged, foreign flows fail to accelerate and current fixed-cost sensitivities prove accurate, the access reform still has operational value. It does not create a positive expected return by itself. The framework must then stand on earnings, price and net cash generation.

If direct custody is uneconomic at the smaller ticket, that rejects the proposed account structure, not necessarily the market. A pooled alternative would still need its own fee, liquidity, distribution and underlying-access diligence. No named listed fund is presented as an allocation. LEGAL

Diligence Actions

The dates below are proposed diligence milestones, not external regulatory deadlines. ESTIMATED

• REQUEST applicant acceptance by 30/10/2026. Contact SNB Capital and the investor's existing international broker. Obtain legal-form and domicile eligibility, account minimums and the exact contracting entity.

• OBTAIN legal and licensing evidence by 06/11/2026. Engage Saudi securities counsel to obtain the current CMA register extract, authorised-activity scope, operative foreign-access provisions and issuer-restriction specification.

• REQUEST competing economics by 06/11/2026. Contact SNB Capital, HSBC Saudi Arabia and Riyad Capital for tax-inclusive custody, brokerage, settlement, corporate-action, FX and outbound-payment terms.

• COMMISSION the liquidity panel by 13/11/2026. Ask the execution provider for security-level daily turnover, spreads, depth, free float and ownership headroom, with normal and stressed exit calculations.

• OBTAIN tax and compliance memoranda by 13/11/2026. Engage Saudi and home-jurisdiction advisers to establish net dividend treatment, listed-gain eligibility, treaty procedure and applicable sanctions nexus.

• SCHEDULE the implementation review for 20/11/2026. Operations and compliance should present the custody-chain map, settlement instructions, cash-release controls and acceptance-test protocol. The review determines whether the operating package clears the screen.

Operator Assessment

This is a sector screen, so founder biographies and venture-funding credentials are not applicable.

The required operator profile is an intermediary capable of documenting applicant acceptance, client-asset treatment, depository connectivity, ownership-limit controls, tax processing, corporate actions and outbound cash handling. Each function needs a named accountable service contact in the final account pack. LEGAL

Provider scale, brand recognition and public partnerships are insufficient substitutes for account-specific service quality. Evidence should include contractual liability allocation, exception handling, reconciliation arrangements and the provider's own relevant settlement-performance record. No market-wide failure rate is assumed.

The portfolio operator additionally needs security-level liquidity analysis and an ownership-control map. A general Saudi research capability does not by itself demonstrate either. ESTIMATED

Conditions

All timelines are proposed milestones. ESTIMATED

Final Verdict

SELECTIVE: broader Saudi market access is established, but an economical account structure with demonstrated stressed exit capacity remains the decisive unresolved condition.

Next Step

This sector screening report is complete and the SELECTIVE verdict is clear, while implementation diligence remains open. REQUEST applicant-specific access and tax-inclusive custody proposals from SNB Capital, HSBC Saudi Arabia and Riyad Capital for the proposed review deadline of 20/11/2026. ESTIMATED

Publication note

Gulf Commercial Insights is commercial diligence intelligence, not investment advice. Gulf Commercial Insights is a brand of Boost My Business AI Innovation Limited, DIFC Trade Licence CL11954.

Sources & References

The following sources support reported claims or provide the specified verification path. A listed URL does not imply that every current rule, tariff or dataset at that location has been independently authenticated.

• CMA, foreign-access announcement, dated 06/01/2026: [2]. Operative access change, supported by legal commentary. REPORTED
• Latham & Watkins, “Saudi CMA Broadens Main Market Access for Foreign Investors”, dated 14/01/2026: [1]. Access and qualification reform. REPORTED
• Gibson Dunn, foreign-investment access and ownership commentary: [6]. Ownership-limit review and regulatory interpretation. REPORTED
• Saudi Exchange, foreign ownership and market publications: [34]. Required current issuer-headroom dataset.
• Argaam, annual market review citing Saudi Exchange statistics: [7]. Historical performance and turnover. REPORTED
• Deutsche Bank, *Marhaba Saudi Arabia 2025*: [13]. Market operations background, supplemented by current Edaa and Muqassa procedures. REPORTED
• SNB Capital, foreign-market-access service announcement: [26]. Provider proposition, not applicant acceptance or licence certification. REPORTED
• MSCI, Saudi Arabia Index and accessibility review: [9] and [32]. Benchmark and operating comparisons. REPORTED
• PwC and ZATCA, withholding and income-tax framework: [16] and [17]. Tax interpretation and statutory verification. REPORTED
• SAMA, monthly monetary statistics: [33]. Currency-reference and macroeconomic verification path. REPORTED
• OFAC, sanctions lists and ownership guidance: [20] and [23]. Current programme, designation and ownership screening. REPORTED
• European Commission and UK OFSI, sanctions framework repositories: [21] and [22]. Applicable restrictions and ownership/control analysis. REPORTED

Evidence key: REPORTED identifies an attributed documentary claim. ESTIMATED identifies a calculation, scenario or analytical inference with its method. LEGAL identifies an interpretation requiring qualified counsel's sign-off. CRITIC identifies a challenge or judgment, not independent factual evidence. No VERIFIED label is used where the available record does not establish the required primary-source authentication.

Reference links

34 cited sources. Links open in a new tab.

How to read this report

Every material claim carries an inline tag showing how the engine sourced it. Read the tag before relying on the claim.

• VERIFIED, checked against a primary register, regulator URL, filing, or official document at publication.
• REPORTED, credible secondary source, named in the claim.
• LEGAL, legal-counsel-style view; sign-off from qualified counsel in the target jurisdiction required before action.
• ESTIMATED, analytical projection with methodology. Directional only, not a disclosed fact.
• CRITIC, adversarial observation or argument, not independent factual evidence.

Appendix: Evidence and Access Map

This appendix shows how every material claim above was sourced and what we confirmed against a primary source.

What we verified, and from where

Each row was confirmed against the primary source shown. The link is live and clickable.

Category C disclaimer (sanctions-sensitive content)

References in this report to sanctioned persons, entities or jurisdictions are included for risk-assessment context only. Gulf Commercial Insights recommends no exposure to, dealing with, or investment in any sanctioned party or sanctioned market, and any supply chain, counterparty or payment route touching such a party is disqualifying. Nothing in this report constitutes investment, legal or sanctions advice; independent sanctions counsel and OFAC, UK OFSI and EU screening are required before any transaction. Material assumptions are stated above. Conditions may change.

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