CMA International Regulatory Cooperation on Digital Assets: Cross-Border Agreements and Standards

Saudi Arabia’s CMA has established the most extensive network of digital asset regulatory cooperation agreements in the Gulf region, with 11 bilateral MOUs and active participation in 4 multilateral forums. This network enables cross-border information sharing, coordinated enforcement actions, and mutual recognition of regulatory standards — critical infrastructure for a tokenization market that is inherently cross-border. The cooperation framework has already facilitated 2 joint enforcement actions and 14 information-sharing requests in its first year of operation.

Bilateral Cooperation Agreements

The CMA has signed digital asset-specific MOUs with 11 international regulators, supplementing existing conventional securities cooperation arrangements:

Gulf Region (4 agreements)

UAE Securities and Commodities Authority (SCA): Signed March 2025, covering mutual recognition of digital asset classifications, cross-border enforcement cooperation, and information sharing on entities operating across both jurisdictions. This agreement has been the most active, facilitating enforcement actions against entities promoting unauthorized digital assets from Dubai to Saudi residents.

Central Bank of Bahrain (CBB): Signed April 2025, focused on tokenized securities cross-listing, mutual recognition of sandbox participation, and coordination on digital asset AML/CFT supervision. Bahrain’s earlier entry into digital asset regulation (2019) provided reference points for the Saudi framework, and the cooperation agreement enables Saudi entities to reference Bahrain regulatory experience.

Qatar Financial Centre Regulatory Authority (QFCRA): Signed June 2025, covering digital asset classification harmonization and supervisory information exchange. Qatar’s more restrictive approach to digital assets creates interesting cooperation dynamics, particularly around the treatment of tokenized sukuk that both jurisdictions have a policy interest in developing.

Central Bank of Kuwait: Signed September 2025, a narrower agreement focused primarily on AML/CFT coordination and sanctions screening for digital asset transactions crossing the Saudi-Kuwait border.

Asia-Pacific (4 agreements)

Monetary Authority of Singapore (MAS): Signed May 2025, comprehensive agreement covering regulatory information sharing, sandbox reciprocity exploration, and joint research on digital asset risk assessment. The MAS agreement is particularly significant given Singapore’s role as a global digital asset licensing hub and the presence of several Singapore-licensed entities in the CMA sandbox.

Hong Kong Securities and Futures Commission (SFC): Signed July 2025, covering cross-border digital asset custody arrangements, token classification alignment, and enforcement cooperation. Hong Kong’s licensing of virtual asset exchanges in 2023-2024 provides regulatory precedents referenced in CMA supervisory guidance.

Securities Commission Malaysia (SC): Signed August 2025, focused on Islamic digital asset securities — the only bilateral agreement with a specific Sharia compliance dimension. The agreement enables mutual recognition of Sharia board certifications for tokenized sukuk distributed in both markets.

Financial Services Agency of Japan (FSA): Signed November 2025, covering security token regulatory cooperation, building on Japan’s advanced security token legal framework enacted in 2020.

Europe (3 agreements)

BaFin (Germany): Signed July 2025, focused on the intersection of EU MiCA regulation with Saudi digital asset rules, enabling smooth cross-border operations for entities operating under both frameworks.

AMF (France): Signed September 2025, covering digital asset service provider regulation and investor protection coordination.

FCA (United Kingdom): Signed October 2025, comprehensive agreement covering regulatory perimeter alignment, enforcement cooperation, and sandpit collaboration. The UK’s significant Saudi business interests make this agreement commercially important for entities seeking cross-border authorization.

Multilateral Forum Participation

IOSCO Fintech Task Force

Saudi CMA representatives participate in IOSCO’s Fintech Task Force, contributing to:

• Global standards for tokenized securities regulation
• Cross-border regulatory perimeter discussions for digital assets
• Investor protection benchmarking for tokenized products
• Decentralized finance regulatory approaches

Saudi input has influenced IOSCO’s 2025 recommendations on tokenized securities disclosure, with the CMA’s disclosure framework cited as a reference model.

Financial Stability Board (FSB)

Saudi Arabia’s FSB membership provides input into global digital asset financial stability assessments. The CMA contributes data on Saudi tokenized securities market size, concentration risk, and systemic interconnections to the FSB’s annual monitoring exercise.

FATF Virtual Assets Contact Group

AML/CFT cooperation through FATF’s dedicated virtual assets working group, contributing to travel rule implementation standards and virtual asset service provider supervisory guidance.

GCC Securities Regulators Forum

Regional cooperation through the GCC Securities Regulators Forum, which established a Digital Assets Working Group in January 2025. The working group is developing harmonized GCC standards for tokenized securities, with the Saudi CMA framework serving as the baseline for discussion.

Cross-Border Enforcement Cooperation

Two joint enforcement actions have been executed through the bilateral agreement network:

1. Saudi-UAE Joint Action (Q4 2025): Coordinated enforcement against an entity operating digital asset promotion targeting both Saudi and UAE residents from a third jurisdiction. The CMA and UAE SCA jointly blocked the entity’s websites and referred the matter to the originating jurisdiction’s law enforcement.

2. Saudi-Singapore Information Exchange (Q1 2026): Information sharing regarding a Singapore-licensed entity seeking CMA sandbox entry, where MAS provided supervisory history and compliance track record data that informed the CMA’s application assessment.

These early cooperation instances demonstrate the practical value of the bilateral agreement network, particularly for addressing the borderless nature of digital asset activities.

Future Cooperation Priorities

The CMA has identified three cooperation priorities for 2026-2027:

1. Mutual recognition framework: Development of a formal mutual recognition regime with 2-3 key jurisdictions (UAE, Singapore, and UK are front-runners), enabling licensed entities to operate across borders with reduced duplicative compliance requirements

2. Joint sandbox initiatives: Bilateral or multilateral sandbox programs allowing entities to test cross-border tokenized securities products under coordinated supervision from multiple regulators

3. Harmonized classification: Working toward consistent digital asset classification standards across GCC jurisdictions, reducing regulatory arbitrage opportunities and facilitating regional capital markets integration

The CMA’s international cooperation strategy positions Saudi Arabia as a constructive participant in global digital asset regulatory development, leveraging the Kingdom’s G20 membership and financial market scale to influence international standards while ensuring Saudi market participants benefit from regulatory interoperability.

Regulatory Intelligence Sharing

Beyond formal enforcement cooperation, the bilateral agreement network supports ongoing regulatory intelligence sharing:

Market Monitoring: Partner regulators share aggregate market data including trading volumes, new licensing applications, and emerging product structures in their jurisdictions. This intelligence informs the CMA’s understanding of global digital asset market trends and competitive positioning.

Risk Assessment: Cross-border risk intelligence enables the CMA to identify entities that have been denied licenses, sanctioned, or placed under enhanced supervision in partner jurisdictions. This information feeds into the CMA’s sandbox application assessment process, where applicants’ international regulatory history is a key evaluation factor.

Technology Assessment: Partner regulators share technical assessments of blockchain protocols, cybersecurity threats, and smart contract vulnerability discoveries. The Saudi Blockchain Lab aggregates this intelligence into technology risk assessments that inform the CMA’s Approved Protocol Registry decisions.

Policy Development: Joint policy research with partner regulators has informed several aspects of the Saudi framework, including the investor protection fund structure (informed by Singapore’s approach), the custody standards (influenced by Swiss and Japanese frameworks), and the Sharia compliance integration (developed in coordination with Malaysia’s Securities Commission).

Impact on Saudi Market Development

International cooperation directly benefits Saudi digital asset market development:

Investor Confidence: International institutional investors assess a jurisdiction’s regulatory framework not in isolation but in the context of its integration with the global regulatory network. Saudi Arabia’s 11 bilateral agreements and 4 multilateral forum memberships signal that the Kingdom’s digital asset market is connected to the global regulatory infrastructure, reducing the “regulatory island” risk that deters international capital.

Cross-Border Product Development: The cooperation network enables product structures that span multiple jurisdictions. A tokenized sukuk issued in Saudi Arabia with cross-border distribution to Malaysia and the UAE benefits from the mutual recognition provisions in the respective bilateral agreements, streamlining investor eligibility verification and custody arrangements.

Talent Mobility: Regulatory cooperation facilitates talent mobility for digital asset professionals. Compliance certifications and regulatory experience recognized in partner jurisdictions support the cross-border movement of expertise that Saudi Arabia’s rapidly growing digital asset sector requires.

Standard Setting Influence: Saudi Arabia’s active participation in IOSCO and FSB digital asset working groups ensures that international standards reflect the Kingdom’s priorities, including Sharia compliance considerations and the unique requirements of Islamic digital securities. The CMA’s G20 membership provides additional weight to Saudi positions in global standard-setting discussions.

The international cooperation framework is not merely a diplomatic exercise — it is infrastructure that enables the cross-border tokenized securities market to function. As sovereign digital sukuk and other Saudi digital securities attract international investment, the bilateral agreement network provides the regulatory channels through which cross-border supervision, enforcement, and investor protection operate.

FATF Integration and G20 Influence

Saudi Arabia’s FATF membership, secured in 2019, provides a critical foundation for international regulatory cooperation in digital assets. As a FATF member, Saudi Arabia participates in setting global AML/CFT standards for virtual assets, ensuring that the Kingdom’s voice shapes international requirements rather than merely implementing externally imposed rules.

The FATF’s 2024 mutual evaluation of Saudi Arabia provided specific commentary on the digital asset regulatory framework, rating it “largely compliant” with FATF Recommendations 15 (virtual assets) and 16 (travel rule). This evaluation outcome strengthens the CMA’s position in bilateral negotiations, as partner jurisdictions can rely on the FATF’s independent assessment as validation of Saudi Arabia’s regulatory standards.

Saudi Arabia’s G20 membership amplifies this influence. The G20’s Financial Stability Board (FSB) has established digital asset regulatory coordination as a priority, and the CMA participates in FSB working groups developing global recommendations for crypto-asset regulation, stablecoin oversight, and DeFi governance. The CMA’s contributions to FSB consultations have influenced global recommendations on custody standards and disclosure requirements, embedding elements of the Saudi framework into international best practices.

Mutual Recognition Framework

The CMA’s mutual recognition framework enables cross-border operations for tokenized securities without duplicative regulatory approval. Under mutual recognition, a tokenized sukuk approved by the CMA can be distributed to investors in partner jurisdictions (currently Malaysia and Bahrain) through a streamlined notification process rather than a full secondary regulatory review.

The framework operates on principles of regulatory equivalence, home-state supervision, and information sharing. The CMA retains primary supervisory responsibility for Saudi-issued tokenized securities, while partner regulators provide investor protection oversight for their domestic investors. This division of supervisory labor reduces compliance costs for issuers and accelerates cross-border distribution timelines, supporting the GCC cooperation objectives that underpin the Kingdom’s regional digital securities strategy.

The mutual recognition framework is expected to expand to include the UAE and Kuwait by end of 2027, creating a GCC-wide tokenized securities distribution corridor that leverages the region’s regulatory harmonization initiatives. For issuers, this corridor would provide access to the combined GCC institutional investor base — approximately $3.5 trillion in assets under management — through a single CMA-approved issuance process.

SEC and ESMA Engagement

Beyond the 11 bilateral MOUs, the CMA maintains informal regulatory dialogue with the US Securities and Exchange Commission (SEC) and the European Securities and Markets Authority (ESMA). While formal bilateral digital asset agreements with these bodies remain under negotiation, the CMA’s participation in IOSCO working groups provides regular engagement on cross-border digital asset regulatory coordination. The SEC’s evolving approach to security token classification under US securities law has influenced the CMA’s own digital asset classification framework, particularly regarding the distinction between Digital Asset Securities and utility tokens. ESMA’s Markets in Crypto-Assets (MiCA) regulation, effective across the EU since 2024, serves as a reference framework that the CMA has benchmarked against in developing disclosure requirements and custody standards.

The CMA’s engagement with PIF-backed entities pursuing international expansion — including firms in the Fintech Saudi accelerator — requires regulatory coordination across multiple jurisdictions simultaneously. The cooperation agreement network provides the channels through which these multi-jurisdictional licensing processes are coordinated, reducing the timeline for Saudi digital asset firms seeking to operate in partner jurisdictions. The Saudi Digital Academy’s regulatory training programs include modules on international regulatory coordination, preparing the next generation of Saudi regulatory professionals for the cross-border supervisory role that the Kingdom’s growing digital asset market demands.

The Saudi Blockchain Lab’s international research collaborations — with MIT Digital Currency Initiative, University College London, and ETH Zurich — complement the CMA’s regulatory cooperation by providing a technical research dimension to cross-border engagement. These academic partnerships generate joint research papers on cross-border settlement protocols, privacy-preserving regulatory reporting, and interoperable smart contract standards that inform both the CMA’s bilateral negotiations and its contributions to multilateral standard-setting bodies. The convergence of regulatory cooperation and technical research collaboration positions Saudi Arabia as both a consumer and contributor to the global digital asset regulatory architecture.

For international cooperation inquiries: info@sauditokenisation.com