Qatar Implements New CbQ Customer Due Diligence Framework: What Foreign-Owned Companies Should Prepare For
In 2025, Qatar is tightening its compliance infrastructure, with the Qatar Central Bank (QCB) introducing a comprehensive update to its Customer Due Diligence (CDD) framework. While much of the regulatory focus is aimed at financial institutions and payment service providers, the implications for foreign-owned companies operating in Qatar—especially those banking locally or using nominee structures—are immediate and substantial.
The changes reflect Qatar’s ambition to solidify its international reputation as a compliant and well-supervised financial centre, aligning with FATF standards and preparing for broader foreign investor participation in its banking and fintech sectors.
A New Standard of Risk Assessment
The revised CDD framework, issued by QCB in early 2025, introduces stricter obligations on financial institutions and designated non-financial businesses and professions (DNFBPs). At its core, the update requires:
- Enhanced verification of UBOs (Ultimate Beneficial Owners), including detailed background checks, documentation, and source of wealth.
- Ongoing monitoring of account activity for consistency with the stated business purpose.
- Risk-based categorization of clients, with heightened scrutiny for passive or foreign-controlled companies.
- Immediate reporting of suspicious inconsistencies, particularly in structures without operational substance in Qatar.
While this is a bank-level regulation, companies—especially those with foreign ownership or external cash inflows—will feel the effects directly. Qatari banks are already implementing stricter onboarding and review policies, leading to longer account opening timelines and more detailed compliance questionnaires.
What This Means for Foreign Companies
If your company is using Qatar as a regional holding location, booking center, or operational base, the expectations around transparency and traceability are now significantly higher. In practice, this means:
- Nominee arrangements and layered ownership must be disclosed with clear documentation.
- Source-of-wealth explanations must now be documented, not simply declared.
- Dormant or inactive entities may trigger compliance flags if account activity doesn’t match the declared business model.
- Annual reviews by banks and service providers are becoming the norm—not the exception.
At Bolster Group, we help clients prepare clean, well-supported onboarding files that pre-empt the questions being asked under the new framework—avoiding delays, clarifications, or worse, silent rejections.
Pressure on Banks, Pressure on Clients
Qatari institutions now face direct accountability for CDD failures under this framework. As a result, relationship managers are more cautious and more selective—especially when onboarding newly formed SPVs, family office structures, or businesses with non-resident ownership.
For foreign companies, this shifts the focus from incorporation to active governance and reporting. It’s no longer enough to hold a license—structures must demonstrate legitimacy, transparency, and business coherence at every level.
Qatar’s updated CDD framework is a strategic compliance move—and a signal that regulatory expectations are rising fast. For foreign-owned companies operating in or through Qatar, it’s time to revisit governance, documentation, and banking posture.
Bolster Group can assist in preparing compliant structures, aligning documentation, and ensuring banking access remains smooth and sustainable in Qatar’s new regulatory environment.