Elite Wall Street boutiques are pushing back against Saudi Arabia’s regional headquarters (RHQ) programme, which requires firms to establish Riyadh-based hubs with at least 15 full-time staff within a year to access government business, including from the $900bn PIF sovereign wealth fund. While Lazard complied by setting Riyadh as its regional base, firms like Moelis, Rothschild, PJT Partners, and Evercore continue using Dubai as their main hub and have not secured RHQ licences despite opening offices in Riyadh. Bankers criticize the ‘one size fits all’ approach, arguing small advisory firms do not need large local teams and that RHQ rules impose unrealistic costs by requiring senior managerial staff rather than revenue generators.

The Ministry of Investment claims over 700 companies are registered, exceeding its 2030 target, with 19 financial institutions licensed and 30 more in the pipeline. Some boutiques have sought exemptions or put applications on hold, with one considering abandoning the licence effort altogether. Hesitation is compounded by weakened capital markets and M&A activity due to regional conflict, and expectations that PIF will focus more inwardly.

Despite frustrations, bankers affirm Saudi Arabia remains a key market and express willingness to maintain operations there—just not under the current RHQ framework.