Raheel Butt
Raheel Butt

Raheel Butt

Partner

Riyadh

+966 50 276 4316
Raheel.Butt@ashurstperkins.com

Introduction

Raheel brings over a decade of on-the-ground Saudi experience advising financial institutions on regulatory compliance, fund structuring, and Shari'ah-compliant investment solutions.

Raheel Butt is a partner in Ashurst Perkins Coie’s Riyadh office and leads the firm’s Saudi Financial Services Regulatory and Funds practice. He has advised on Saudi financial services, investment funds and capital markets matters since 2008, with a particular focus on CMA regulated activities, investment fund structuring, asset management, brokerage and dealing models, custody, securities financing and cross border financial services arrangements.

Raheel advises international and domestic financial institutions, asset and fund managers, fund sponsors, brokers, custodians, banks and sovereign-related entities on a range of financial services matters include market entry into Saudi Arabia, regulatory perimeter advice, fund establishment and documentation, regulated operating models and the application of Saudi financial regulatory frameworks to complex and novel transactions. His practice regularly involves advising on the interaction between CMA, SAMA and broader Saudi regulatory requirements.

He is experienced on Saudi investment fund structure, including real estate funds, private equity funds, private credit structures, Shariah-compliant investment products, fund platforms and bespoke asset holding and investment structures. He regularly advises on fund terms and conditions, fund governance, investor participation models, in-kind distributions, fund wind-downs, discretionary portfolio management arrangements.

Clients value Raheel for his deep knowledge of the Saudi regulatory landscape, his ability to translate complex regulatory issues into practical and commercially viable solutions, and his experience advising on high-profile and strategically significant mandates involving leading global financial institutions, major Saudi market participants and sovereign related entities.

CMA licensing, market entry and regulatory perimeter

  • Advising large international online brokerage platform on its CMA licensing application and Saudi market entry strategy, including the regulatory structuring of its proposed securities business activities in the Kingdom.
  • Advising a number of leading international banks, broker-dealers and financial institutions on Saudi financial regulatory issues, cross-border activity, client access, regulatory perimeter analysis and permissible operating models.

Investment funds, asset management and private capital

  • Advising Jeddah Central Development Company on investment structuring for major strategic real estate and hospitality-led development projects, including fund and corporate structuring alternatives, governance, asset holding arrangements and sponsor / investor protections.
  • Advising SICO Capital on regulatory and commercial matters relating to Saudi investment funds, including fund wind-down, in-kind distributions and investor facing arrangements.
  • Advising SNB Capital on Saudi regulatory and fund-related matters, including private credit, factoring / reverse factoring structures, offshore SPC arrangements and Shariah-compliant investment structures.

Financial product regulatory analysis

  • Advising a leading global investment bank on Saudi regulatory issues relating to stock lending, pay-to-hold arrangements and GMSLA-related structures, including the application of Saudi securities lending rules and CMA regulatory perimeter considerations.
  • Advising international financial institutions on Saudi regulatory issues relating to repo, securities financing and derivatives linked arrangements, including the interaction between SAMA repo guidance, CMA securities business rules and Saudi netting related considerations.

Brokerage, custody and securities market access

  • Advising an international investment bank on Saudi regulatory and operating model issues relating to primary dealer activity in Saudi government debt instruments, including local CMI support arrangements, auction participation, secondary market activity, custody, settlement and market infrastructure considerations.

Governance, AML and regulatory compliance

  • Advising a leading global investment bank on Saudi governance and regulatory matters, including internal governance, client coverage and regulatory support arrangements.
  • Advising Saudi and international clients on Saudi Personal Data Protection Law compliance and cross-border data transfer arrangements.

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