Law & Regulation
Law No. 20 of 2019 on Combating Money Laundering and Terrorism Financing
The Law is Qatar's principal framework for criminalising money laundering and terrorism financing, imposing preventive duties on financial institutions and designated non-financial businesses and professions, requiring beneficial-ownership and transaction scrutiny, supporting suspicious-transaction reporting, empowering competent authorities and enabling restraint, confiscation and international cooperation.
Legal Significance
What This Instrument Does
Combines criminal prohibitions with a risk-based preventive system. It allocates obligations among regulated businesses, supervisors, the financial intelligence function, investigators, prosecutors and courts, while establishing information-sharing and cross-border cooperation mechanisms.
Why It Matters
Infrastructure transactions involve high-value, cross-border, multi-party flows and public counterparties. The Law affects onboarding, beneficial-ownership verification, source-of-funds analysis, payment monitoring and reporting. Those requirements operate independently of whether the underlying project contract or financing is commercially valid.
Key Provisions
- Money-laundering offence
Conduct by which proceeds are converted, transferred, concealed, possessed or used with the required criminal connection and mental element.
- Terrorism-financing offence
Prohibition and liability framework for providing or collecting funds for prohibited terrorist purposes.
- Predicate offences and proceeds
Broad connection between criminal proceeds and laundering exposure, including cross-border dimensions subject to legal tests.
- Risk-based preventive duties
Institutional assessment and controls calibrated to customer, geography, product, channel and transaction risk.
- Customer due diligence
Identification and verification of customers, representatives, purpose and ongoing relationship information.
- Beneficial ownership
Identification of the natural person(s) who ultimately own or control, distinct from the immediate legal customer.
- Enhanced and simplified measures
Differentiated treatment where risk factors justify greater scrutiny or legally permitted simplification.
- Politically exposed persons
Additional approval, source and monitoring measures for covered PEP relationships.
- Record keeping and internal controls
Retention, policies, governance, training, audit and compliance-function requirements.
- Suspicious transaction reporting
Reporting to the competent financial intelligence authority and restrictions on tipping-off.
- Supervisory powers
Risk-based supervision, inspection, directions and administrative sanctions by competent supervisors.
- Investigation and provisional measures
Access to information and mechanisms for tracing, freezing or restraining suspected assets under lawful authority.
- Confiscation and sanctions
Criminal and administrative consequences, including confiscation architecture.
- Legal persons and responsible persons
Liability and consequences involving entities and persons directing or controlling conduct, without converting the Law into companies legislation.
- International cooperation
Mutual assistance, information exchange and coordination subject to statutory conditions.
When You Would Use This
KYC and beneficial-ownership diligence
Verifying customer identity and beneficial ownership.
Counterparty onboarding
Onboarding lenders, sponsors, contractors and investors.
Payment and account controls
Designing payment and account controls.
Sanctions / PEP escalation
Escalating sanctions and politically-exposed-person issues.
Transaction monitoring
Designing transaction-monitoring processes.
Internal compliance design
Building internal AML/CFT compliance programmes.
Suspicious-activity decisions
Deciding whether to file a suspicious-transaction report.
Acquisition diligence
Conducting AML/CFT diligence on an acquisition.
Enforcement / asset-freezing risk review
Reviewing enforcement or asset-freezing exposure.
InfraLex Relevance
The Law supplies a compliance lens across the project lifecycle: counterparty identity, ownership, source and destination of funds, unusual transaction patterns and escalation. InfraLex must keep this separate from commercial bankability analysis and should not imply that completed KYC proves project legality or integrity.
Legal Framework Position
- Banking & FinanceSupporting / Related Instrument
Related / Implementing Instruments
Instrument Overview
- Official Citation
- Law No. 20 of 2019
- Instrument Type
- Law / Act
- Source Language
- Arabic
- Last Verified
- 4 September 2026