Cross-border marketing of securities in Qatar requires careful navigation of a complex regulatory landscape shaped by local laws, international standards, and the unique framework of the Qatar Financial Centre (QFC). Foreign financial institutions must consider the following key areas when accessing Qatari clients:

Regulatory Authorities and Licensing

Qatar Central Bank (QCB)

The QCB oversees all financial activities under Law No. 13 of2012, which prohibits unlicensed financial services in Qatar, including cross-border transactions perceived as operating within the country. Foreign institutions must assess whether their activities—such as marketing securities to Qatari residents or facilitating transactions—trigger licensing requirements. Penalties fornon-compliance include fines up to QAR 5 million and imprisonment.

Qatar Financial Markets Authority (QFMA)

The QFMA regulates securities under Law No. 8 of 2012, mandating licensesfor brokers, dealers, and investment advisers. Cross-border marketing that targets Qatari investors may require QFMA approval, particularly if it involves advice on locally listed securities or market manipulation risks under the Code of Market Conduct (2025).

Qatar Financial Centre Regulatory Authority (QFCRA)

The QFC offers a separate legal jurisdiction with English common law principles, allowing 100% foreign ownership. Institutions operating within the QFC must comply with QFCRA rules but benefit from exemptions from certain QCB restrictions, provided activities are confined to the QFC.

Key Regulatory Concerns

Anti-Money Laundering (AML) Compliance

Qatar’s AML Law No. 20 of 2019 requires:

• Customer Due Diligence (CDD) for all clients, including verification of beneficial ownership.
• Suspicious Transaction Reports (STRs) to the Qatar Financial Information Unit (QFIU) within 24 hours of detection.
• Record-keeping of transactions for at least 10 years.

QFC-based firms must also adhere to the QFC Anti-Money Laundering Regulations, aligned with FATF standards.

Market Conduct and Transparency

The Code of Market Conduct (2025) prohibits:

• Market manipulation, including false impressions of trading activity or artificial price-fixing.
• Insider trading or undisclosed conflicts of interest.

Foreign institutions must ensure marketing materials avoid misleading claims about securities’ performance or risks.

Cross-Border Enforcement

The QCB’s 2024 Guidance on Enforcement emphasizes cooperation with international regulators and penalties for violation simpacting Qatar’s financial stability. Activities deemed to harm local investors or markets—even if conducted off shore—may face scrutiny.

Structural Considerations

Foreign Ownership Restrictions

Under Law No. 1/2019, foreign investors may own up to 100% of companies  in most sectors subject to approval from the Ministry of Commerce and  Industry.  However, foreign ownership  in Qatari listed joint stock companies is capped at 49% unless increased by  Council of Ministers’ approval.   Stricter limits apply to excluded sectors, including banking and  insurance and natural resources, where foreign ownership is generally  restricted to 49% or lower. The QFC permits full foreign ownership, making it  a preferred gateway for cross-border activities.

Digital Securities and CBDC

The QCB’s Wholesale Central Bank Digital Currency (wCBDC) Program (2025) aims to streamline cross-border securities settlements using distributed ledger technology. Institutions should monitor developments, as future integration may reduce transactional friction but introduce new compliance requirements.

Areas of Risk Mitigation

1. Licensing Clarity: Confirm whether marketing activities require QCB, QFMA, or QFCRA approval.
2. AML Protocols: Implement systems to detect suspicious transactions and report to the QFIU.
3. Disclosure Standards: Ensure transparency in client communications to avoid allegations of market abuse.
4. QFC Structuring: Consider establishing a QFC entity to leverageregulatory flexibility and English-law contracts.

Foreign institutions must engage local legal counsel to navigate Qatar’s evolving regulatory environment, particularly as the QCB expands its digital infrastructure and cross-border oversight.

The team at Al Ansari Law regularly counsel, directlyor indirectly through international law firm collaborations, on mattersrelating to cross-border marketing of securities.

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