Establishing and verifying a client’s source of wealth is one of the most challenging aspects of financial compliance. Global regulatory bodies such as the Financial Action Task Force (FATF)1 and the European Union’s Anti-Money Laundering (AML) directives acknowledge these difficulties, urging institutions to adopt a risk-based approach. This involves balancing public domain research with client disclosures — a task that becomes even more complex in regions where transparency is limited.
Table of contents
Regional challenges in the Middle East and Africa
Key wealth indicators in the MEA Region
Corporate shareholdings
Family connections
Positions of patronage
Real estate ownership
Pulling it all together
For sectors dealing in high-value transactions — including private banking, real estate, casinos, and currency exchange — verifying source of wealth is not just a compliance requirement; it’s a critical element of commercial risk management.
Regional challenges in the Middle East and Africa
Identifying the source of wealth for individuals in the Middle East and Africa (MEA) can be particularly demanding. Outside of high-profile business figures or royals listed in publications like the Forbes Rich List, there is often little reliable, public information to go on.
Key obstacles include:
Despite these challenges, several indicators can help paint a reliable picture of a client’s source of wealth.
Key wealth indicators in the MEA Region
Wealth in the Middle East and North Africa is often closely tied to family lineage. A clear view of an individual’s family tree can reveal connections to:
Although less concrete, roles of influence — particularly within a diwan (royal court) or other government-affiliated bodies — often come with significant financial benefits. These positions are typically based on trust and close proximity to power, both of which may indicate access to considerable resources, even if not directly salaried.
This also overlaps with identifying Politically Exposed Persons (PEPs), and further due diligence is usually warranted.
Property holdings are another route for wealth assessment, though data availability varies across jurisdictions. In some MEA countries, land and property records can be accessed, and Diligencia provides this service in several markets. However, identifying real estate assets is rarely quick or easy, especially when records are held in paper or offline formats.
Pulling it all together
When onboarding a client from the MEA region, indicators often need to be triangulated.
Consider a hypothetical example: The client is the son of a chief adviser to a royal court, a director in a multi-generational family business, and a shareholder in a large Gulf-based financial institution.
In such a case, even without complete documentation, a reasonable and well-supported narrative for the source of wealth can be established.
While verifying the source of wealth in Africa and the Middle East comes with regional complexities, it is far from impossible. Leveraging local insight, structured data, and specialist tools can help compliance teams bridge the gap between regulatory expectation and practical feasibility.
At Diligencia, we continue to develop solutions tailored for this very purpose.
Diligencia helps customers from around the world to find essential information on organisations registered in Africa and the wider Middle East, drawing on primary sources that are otherwise hard to find. Using our curated data, we enable our clients to effectively manage their compliance obligations, allowing them to continuously monitor their suppliers and counterparty risks in the MEA region.