← Regulations / Saudi Arabia / Operating Models / Self-custodial wallet

Self-custodial wallet / non-custodial software in Saudi Arabia

Publisher of software where users hold their own private keys. The publisher never holds, controls, or has access to user funds.

Not permitted AI-Generated · Unreviewed

Self-custodial wallet is not permitted in Saudi Arabia.

Verdict Details

Permitted
no
Local entity required
No
Licensing burden
High
Last updated
2026-07-13

Key Restrictions

  • Virtual assets (including self-custodial wallet software) are declared illegal/unlicensed per the 2018 Standing Committee declaration by SAMA/CMA/MOF
  • Publishing self-custodial wallet software for Saudi residents would constitute facilitating access to virtual assets, which is outside the legal framework
  • No recognized licensing pathway exists for non-custodial software because all crypto activities fall outside approved perimeters
  • SAMA warnings against Bitcoin and virtual currencies remain ongoing with no oversight or support

Key Risks

  • Regulatory enforcement action — SAMA and MOF have publicly warned that crypto activities are outside the legal framework and unlicensed actors face legal action
  • The 2018 Standing Committee declaration treats all virtual asset activities as illegal — software publishers could be seen as facilitating illegal activity
  • No AML obligations can be lawfully discharged because there is no legal framework to register or comply through
  • Reputational and operational risk of serving residents of a jurisdiction where the activity is affirmatively prohibited

Evidence

This verdict synthesizes the following facts. Each fact links to its primary source(s).

licensing 60% confidence

2018 Standing Committee Declaration (via SAMA/CMA): Virtual assets illegal/unlicensed.

[primary] sama.gov.sa [primary] sama.gov.sa — RegulatorySandbox [primary] https://misa.gov.sa[1
licensing 20% confidence

2018 Standing Committee declaration (SAMA/CMA/MOF): Virtual currencies illegal. (https://www.lightspark.com/knowledge/is-crypto-legal-in-saudi-arabia)

licensing 20% confidence

SAMA warnings against Bitcoin (ongoing): No oversight or support. (https://zipmex.com/blog/is-crypto-mining-legal-in-saudi-arabia/) ; (https://freemanlaw.com/cryptocurrency/saudi-arabia/)

licensing 20% confidence

MOF 2019 warning: Outside legal framework. (https://timesofindia.indiatimes.com/world/middle-east/saudis-bitcoin-trading-laws-2025-what-traders-and-businesses-need-to-know/articleshow/124017628.cms)

licensing 60% confidence

No standardized licenses: There is no broadly public VASP (Virtual Asset Service Provider) or crypto-specific license for retail exchanges, custody, or payment processing; activities like crypto trading, wallet services, or brokerage fall outside approved perimeters without explicit regulatory approval.

[primary] sama.gov.sa [primary] sama.gov.sa — RegulatorySandbox [primary] https://misa.gov.sa[1
licensing 60% confidence

Limited permitted activities: Under SAMA's 2023 Payment Service Provider Regulations (enabled by the 2022 Law of Payments and Payment Providers), related services such as digital banking, electronic payment processing, P2P lending/investment, asset/wealth investment, crypto/blockchain applications, and BNPL may qualify indirectly, but not pure crypto trading or custody.

[primary] sama.gov.sa [primary] sama.gov.sa — RegulatorySandbox [primary] https://misa.gov.sa[1
licensing 20% confidence

Custodial License Requirements: None exist, as no licenses are issued for cryptocurrency practices; entities claiming otherwise face legal action.

licensing 60% confidence

Exchanges and custody: Require entry via SAMA's Regulatory Sandbox as the primary (and currently only recognized) route for testing and potential approval; full operations demand ongoing compliance verification.

[primary] sama.gov.sa [primary] sama.gov.sa — RegulatorySandbox [primary] https://misa.gov.sa[1
licensing 60% confidence

Primarily a licensing regime with sandbox entry: Business registration alone (e.g., via Ministry of Investment - MISA portal) is insufficient; it precedes a preliminary sandbox application to SAMA for crypto-related activities. No "one-click" registration substitutes for licensing, and unlicensed operations face administrative penalties, unannounced inspections, and potential legal action.

[primary] sama.gov.sa [primary] sama.gov.sa — RegulatorySandbox [primary] https://misa.gov.sa[1

Verdict Attribution

Source:
AI-Generated · Unreviewed
AI synthesized:
2026-07-13 (deepseek-chat)
Last updated:
2026-07-13
Confidence:
high

This verdict was produced by an AI model from the underlying facts. Confirm with counsel before relying on it for material decisions.

Not permitted — virtual assets are declared illegal in Saudi Arabia per the 2018 Standing Committee (SAMA/CMA/MOF) declaration; publishing self-custodial wallet software that enables Saudi residents to interact with cryptocurrencies would fall outside the legal framework, and no licensing pathway exists for such activity.

Questions this verdict aims to answer

  • Does software publishing trigger VASP / MSB classification?
  • Do AML obligations attach when no custody exists?
  • What disclosure or consumer-protection rules apply?