PUAS LLC
- Executive summary
- The problem
- The solution and legal insight
- How it works
- Regulatory framework
- Market size and opportunity
- Customer validation
- Business model
- The Bali Restaurant chain
- Unit economics
- Competitive landscape
- Financial projections
- Use of funds
- Deal structure and investor terms
- Returns and downside protection
- Risk factors
- The founder
- Open items before close
- Next steps
Executive summary
PUAS LLC is a MISA-registered Saudi limited liability company operating as a licensed Tour & Travel Agency. It solves a structural payment problem that has persisted for decades: Indonesian Umrah and Hajj travel agents cannot legally settle Saudi hotel invoices in Riyals without a Saudi legal entity — and none of them has one.
PUAS is that entity.
When an Indonesian agent routes a hotel invoice through PUAS, the agent pays PUAS in IDR for a travel service package. PUAS settles the hotel in SAR as a B2B transaction inside the Kingdom. No currency crosses a border. No remittance occurs. Three explicit SAMA regulatory exemptions confirm this structure is commerce, not remittance.
The legal insight is the moat. No fintech application, bank, or money transfer operator can replicate it without a Saudi LLC, a Tour Agency licence, and a local Riyal pool. Building those assets took the founder more than two years and SAR 750,000 of personal capital. They are already in place.
The raise
Base case returns — 25% equity stake
| Scenario | Year 5 MOIC | IRR | Year 2 cash-on-cash |
|---|---|---|---|
| Conservative | 3.1× | 25% | ~11% |
| Base case | 8.0× | 51% | ~22% |
| Optimistic | 13.1× | 67% | ~40% |
Downside protection: SAR 2.75–3.1M of SAR 5M is recoverable in a wind-down scenario. 52% of the raise sits in recoverable working capital assets on Day 1. This is exceptional protection for a seed-stage investment.
The problem
Every year, more than 2 million Indonesian pilgrims travel to Saudi Arabia for Umrah and Hajj. More than 2,600 licensed Indonesian travel agents — PPIUs — handle their hotel bookings. Those hotels are in Mecca and Medina. They invoice in SAR. The agents hold IDR.
Paying a Saudi hotel in Riyals from Indonesia, through a legal channel, is harder than it sounds. Agents face two options:
Option A — Bank wire (SWIFT)
Legal, but costly and slow. Indonesian banks charge wire fees plus an FX spread of 0.8–1.3% above mid-market — a total effective cost of 3–5% including spread. Settlement takes 2–3 weeks. Banks require extensive documentation with no Indonesian-language support on the Saudi side. For large seasonal transfers timed to pilgrim group departures, the timing mismatch is operationally damaging.
Option B — Hawala or informal USDT
Fast and cheap — typically near mid-market — but illegal under SAMA regulations and Saudi AML law. Agents who use informal channels carry full criminal liability with no documentation trail, no recourse if funds go missing, and no protection if the network collapses.
Most agents choose Option B. This is not ideology. It is rational economics in the absence of a legal alternative that works.
The structural nature of the gap
The gap is not a product gap. Banks have the licence but have not built the product. MTOs have the product but lack a Saudi legal entity. Fintech applications have the interface but no Saudi-side entity at all.
The World Bank Remittance Prices Worldwide database has no data for the Indonesia → Saudi Arabia corridor. The reverse corridor (Saudi → Indonesia labour remittances) is fully documented. The absence of outbound IDR→SAR data reflects the fact that no formal B2B settlement channel exists for Indonesian agents paying Saudi hotels. That is the gap PUAS fills.
The solution and legal insight
PUAS discovered that the third option — one that has always been legal — was never built into a product.
A licensed Tour & Travel Agency does not send money to Saudi Arabia. It pays a vendor invoice inside Saudi Arabia. That is not remittance. That is commerce.
The mechanism: an Indonesian agent pays PUAS in IDR for a travel service package. PUAS — as a Saudi-registered Tour & Travel Agency — pays the Saudi hotel in SAR as settlement of its own supplier invoice. No payment account is created in the agent's name. No currency crosses a border. No money transfer occurs. Three SAMA regulatory exemptions confirm this position explicitly.
Why the moat is structural
No competitor can enter this market quickly. To replicate PUAS, a competitor needs:
- A MISA-registered Saudi LLC with Travel & Tourism activity codes — over two years for PUAS to establish
- A Ministry of Tourism Travel & Tourism Agency licence — dependent on the LLC being in place first
- A local Riyal pool large enough to fund settlement float and offer net-7 terms to agents
- A founder who understands both the Saudi regulatory environment and the Indonesian PPIU market simultaneously
The combination of these four assets cannot be replicated in less than two years from standing start. PUAS has all four today.
How it works
The five-step mechanism
| Step | Action | Jurisdiction | Legal basis |
|---|---|---|---|
| 01 | Agent re-routes hotel invoice to PUAS | Indonesia | Standard B2B service request |
| 02 | Agent pays PUAS in IDR for a travel service package | Indonesia | IDR commercial service transaction — Bank Indonesia compliant |
| 03 | PUAS pays Saudi hotel in SAR | Saudi Arabia | B2B vendor payment — SAMA compliant, no remittance |
| 04 | PUAS earns margin from hotel wholesale discount | Saudi Arabia | Licensed travel agency purchasing power |
| 05 | Volume grows pool; pool grows discount; discount attracts more agents | Both | Commercial flywheel |
The Riyal pool
The SAR does not come from Indonesia. It comes from inside Saudi Arabia:
- The Bali Restaurant (Al-Khobar): daily SAR revenue, zero FX cost
- Hotel allotment commissions: paid in SAR by Saudi hotels as volume grows
- Settlement float from raise: SAR 2 million dedicated reserve, Day 1 of agent flow
The pool is both the operational engine and the switching moat. ActionPay requires IDR prepayment. PUAS can offer agents net-7 settlement terms — the hotel is booked and confirmed before IDR clears. No competitor can offer this without the same SAR reserve.
Regulatory framework
Saudi side — confirmed positions
Three explicit SAMA exemptions
| Provision | Effect |
|---|---|
| Article 7(2) — Implementing Regs, Law of Payments and Payment Services (2023) | A commercial agent selling services to a foreign buyer is not providing a payment service |
| Article 7(16) — same regulations | Where no payment account is created in the customer's name, no remittance occurs |
| Article 4(b) — Rules Regulating Money Changing Business | Travel agencies in KSA are explicitly authorised to handle customer foreign currency, provided the FX leg routes through a licensed bank with AML documentation |
Saudi entity status
| Licence / registration | Status |
|---|---|
| MISA registration | Held & active |
| Commercial Registration — Travel & Tourism activity codes | Held & active |
| Ministry of Tourism Travel & Tourism Agency licence | Ready to file — 5–10 days processing |
Nusuk Masar — structural tailwind (June 2025)
Saudi Arabia now mandates all Umrah hotel bookings be confirmed through Nusuk Masar before a visa is issued. Foreign agents cannot access the platform directly — they must route through a Saudi-registered entity. The PUAS function has moved from being competitively advantaged to being a regulatory requirement.
AML obligations (Saudi side)
PUAS is not a DNFBP under Saudi AML law — travel agencies are absent from the designated list. General AML obligations apply: CDD/KYB on every PPIU, beneficial owner identification, source-of-funds documentation, 10-year record retention, suspicious transaction reporting via GoAML, and sanctions screening. Supervisory authority: Ministry of Commerce and Investment, not SAMA.
Indonesian side — confirmed positions
The PPIU pays its Indonesian bank in IDR. The bank converts and remits to PUAS's Saudi account via SWIFT. IDR cannot be physically transferred abroad under PBI 16/17/PBI/2014. PPIUs are not Pihak Pelapor (reporting parties) under PP 43/2015 — the PPIU's bank files all cross-border reports automatically.
Entity structure (Indonesia): An Indonesian PT collecting IDR and remitting to PUAS Saudi is explicitly not viable — this would constitute an unlicensed remittance service under PBI 23/6/PBI/2021 with criminal exposure under UU 3/2011. Direct SWIFT wire from PPIU's bank is the recommended and legally clean approach.
Known unknowns — disclosed to investors
| # | Issue | Priority | Mitigation |
|---|---|---|---|
| 1 | UU 8/2019 Pasal 94(d): whether MoT licence satisfies "izin resmi from Government of KSA" requirement | High | Indonesian counsel legal opinion being obtained |
| 2 | MoT licence filing timing | High | File before investor meetings; 5–10 day processing |
| 3 | Saudi bank AML treatment of inbound IDR flows at volume | Medium | Maintain thorough AML documentation from Day 1 |
| 4 | No tested case law on this specific structure | Medium | Three explicit exemptions; position strong on face of regulation |
| 5 | UU 14/2025: individual Umrah legalised outside PPIU channel | Medium | Disclose; PUAS function is relevant regardless of booking channel; 2,600-agent PPIU base unaffected near-term |
Market size and opportunity
Hotel spend — the addressable pool
| Segment | Volume (2024) | Hotel spend / pilgrim | Hotel TAM |
|---|---|---|---|
| Hajj | 241,000 | ~SAR 4,233 (BPIH 2025 official) | SAR ~1.0B |
| Umrah (PPIU-registered) | 1,400,000 | ~SAR 430 (4-star quad-share, 9 days) | SAR ~0.6B |
| Umrah (non-PPIU) | 400,000 | ~SAR 430 | SAR ~0.17B |
| Total | ~2.04M | ~SAR 1.8–2.5B |
PUAS penetration targets
| Year | Target agents | % of PPIUs | Annual gross bookings |
|---|---|---|---|
| Year 1 | 30 | 1.2% | SAR 37.5M |
| Year 3 | 80 | 3.1% | SAR 210.6M |
| Year 5 | 220 | 8.5% | SAR 626.4M |
PUAS does not need to dominate the market. Year 5 at 220 agents captures less than 2% of the conservative hotel spend TAM. The penetration story is minimal risk, substantial reward.
Customer validation
The founder conducted direct conversations with approximately 10 Indonesian PPIU agents and one executive at ActionPay — Bank Indonesia-licensed MTO serving 250+ Hajj and Umrah agents.
Key findings
| Finding | Detail |
|---|---|
| Switching trigger | 0.5–1% better rate is enough to move an agent. Price is the primary driver, not compliance posture. |
| Volume per agent | SAR 100K–1M per month. 4–15 transactions per month (group departure cycles). Average transaction: SAR 20K–100K+. |
| Volume discounts | No volume discount available from any existing provider — larger agents pay the same rate as small ones. Explicit pain point. |
| Primary objection | Inertia, not ideology. Agents don't switch unless they can see what they're leaving on the table. |
| Platform demand (unsolicited) | Every agent raised food, transport, and Saudi-side services unprompted. They see PUAS as a platform, not a payment channel. |
| Ownership desire | Agents want to own a stake in the Saudi-side business. The Tranche B SPV structure directly answers this signal. |
Quotable signals from direct interviews
"If you can make the rate cheaper, we will move."
"With PUAS we can unlock other opportunities — food, transportation, services for pilgrims on the Saudi side. We want to be part of that."
"The problem is not trust in principle. We need to see what we are missing by not using PUAS."
Business model
Revenue stream 1 — Hotel settlement margin
PUAS buys hotel room inventory at wholesale from Mecca and Medina properties, settles agents' hotel invoices at a competitive rate, and retains the spread. Entry via B2B platforms (WebBeds, MaqamUmrah) available immediately via MISA registration. Discount curve deepens as volume unlocks direct allotment contracts.
| Year | Discount source | Gross discount off rack | Passed to agents | Net margin |
|---|---|---|---|---|
| Year 1 | B2B platforms + first direct | 22% | 15% | ~4% |
| Year 2 | Standard wholesale (direct) | 30% | 22% | ~5.5% |
| Year 3 | Preferred-partner + allotment | 38% | 28% | ~7.5% |
Revenue stream 2 — The Bali Restaurants
Indonesian F&B brand in Saudi Arabia. Al-Khobar open. Jeddah launching from raise capital. Daily SAR revenue — the Riyal pool anchor. Mecca and Medina locations follow the agent network, enabling meal bundling in pilgrim packages. See Section 9 for full detail.
Revenue stream 3 — Transport and pilgrim services
Ground transfers, coach charters, and all Saudi-side pilgrim services. Demand signal confirmed unsolicited in every agent interview. Modelled conservatively: zero Year 1, SAR 250K Year 3, SAR 1.8M Year 5.
The flywheel — quantified
| Stage | Mechanism | Numbers (base case) |
|---|---|---|
| Agent acquisition | PUAS offers 0.75% better than ActionPay | SAR 281K subsidy cost, Year 1 |
| Hotel volume accumulates | 30 agents × SAR 162K/month hotel | SAR 47M hotel volume/year |
| Hotel margin covers subsidy | 4% margin on SAR 47M | SAR 1.9M revenue covers SAR 281K subsidy 6.8× |
| Discount deepens | Volume crosses tier thresholds | Net margin 4% → 5.5% → 7.5% |
| Rate subsidy tapers | Hotel margin and net-7 terms become the moat | Subsidy zero from Year 4 |
| More agents switch | Better rate + net-7 terms + platform depth | 30 → 80 → 220 agents |
The Bali Restaurant chain
The Bali serves three functions: (1) the SAR pool anchor that makes the hotel settlement mechanism self-sustaining, (2) the pilgrim service bundle in Mecca and Medina, and (3) a physical proof that PUAS is a real operating company in Saudi Arabia.
Investment and rollout plan
| Location | Investment | Status | Funding source |
|---|---|---|---|
| Al-Khobar | SAR 400,000 | Open | Founder capital (deployed) |
| Jeddah | SAR 750,000 | Months 3–9 from raise | From raise capital |
| Location 3+ | ~SAR 400K each | Year 3 onward | Restaurant operating profit |
Monthly cash flow per location (base case)
| Period | Net cash / month | Notes |
|---|---|---|
| Months 1–3 | –SAR 12,000 | Ramp, pre-maturity |
| Months 4–6 | +SAR 3,000 | Near breakeven |
| Months 7–12 | +SAR 14,000 | Growing covers |
| Month 13+ | +SAR 21,500 | Mature base case |
5-year chain economics (base case)
| Year | Locations | Net chain revenue |
|---|---|---|
| Year 1 | 2 | SAR 44,000 |
| Year 2 | 2 (both mature) | SAR 471,000 |
| Year 3 | 3 | SAR 450,000 |
| Year 4 | 5–6 | SAR 1,200,000 |
| Year 5 | 7–8 | SAR 1,800,000 |
Payback per location: 28–36 months at base case. Locations 3+ are self-funded from Year 2 restaurant operating profit — no additional raise capital required beyond Jeddah.
Unit economics
Exchange rate — the competitive benchmark
The real benchmark is ActionPay — the market's best-priced licensed MTO, already operating near mid-market. PUAS does not need to beat banks. It needs to beat ActionPay.
| Channel | IDR/SAR | Spread vs. mid-market |
|---|---|---|
| Indonesian banks (BCA, BNI) — SWIFT | 4,687–4,712 | +0.8–1.3% |
| ActionPay (MTO competitor) | ~4,612–4,662 | ~0–0.3% over mid |
| Grey market (USDT round-trip) | ~4,700–4,750 | ~+1.1–2.2% vs. mid |
| PUAS target (Year 1) | ~4,580–4,615 | 0.75% better than ActionPay |
Settlement float — the dominant capital item
PUAS pays hotels at or before check-in. IDR arrives T+1 to T+3 (5–14 calendar days float gap).
| Daily settlement (30 agents) | Float period | Required reserve |
|---|---|---|
| SAR 120,000/day | 14 days + 25% buffer | SAR 2,000,000 |
The settlement float is a recoverable balance sheet asset, not a sunk cost. It earns ~5% SAIBOR (~SAR 100K/year) and is returned in full at wind-down. It is also the switching moat — ActionPay requires IDR prepayment; PUAS can offer net-7 terms.
Break-even per agent
Hotel margin per agent per month: 4% × SAR 162,500 (hotel share) = SAR 6,500. Subsidy cost per agent (0.75% × SAR 250K): SAR 1,875. Net contribution: SAR 4,625/agent/month. Break-even at the agent level: month 4–6.
Competitive landscape
| Alternative | What they have | What they lack | PUAS advantage |
|---|---|---|---|
| Indonesian banks (SWIFT) | Regulatory licence | Speed, IDR interface, hotel settlement function | 3–5× cheaper, 10× faster, fully documented |
| ActionPay (MTO) | Near-market pricing, 250+ agent relationships | Saudi legal entity — cannot settle hotel invoices as B2B | Legal B2B settlement + net-7 terms + volume discounts |
| Fintech remittance apps | Interface | Saudi entity — no hotel B2B settlement possible | Saudi LLC already registered; 2+ year head start |
| Hawala / USDT | Speed, cost | Legal standing, documentation, recourse | Legal alternative at comparable cost — removes criminal risk |
Barriers to competitive entry
- Regulatory: New entrant starting the MISA + CR + MoT process today would not be operational before mid-2027 at the earliest
- Capital: SAR 2 million settlement float cannot be substituted by technology or relationships
- Founder credibility: 25+ years in Saudi Arabia, Premium Residence Iqama, bilateral regulatory knowledge — not replicable by hiring
Financial projections
Three scenarios: Conservative / Base case / Optimistic. All figures SAR thousands unless noted. Year 1 = 12 months from raise close.
Agent ramp
| Year end | Conservative | Base case | Optimistic |
|---|---|---|---|
| Year 1 | 15 | 30 | 50 |
| Year 3 | 55 | 80 | 120 |
| Year 5 | 150 | 220 | 300+ |
Total net revenue (SAR thousands)
| Stream | Y1 | Y2 | Y3 | Y4 | Y5 |
|---|---|---|---|---|---|
| Hotel settlement margin | 975 | 4,547 | 10,267 | 20,420 | 36,644 |
| The Bali Restaurants | 44 | 471 | 450 | 1,200 | 1,800 |
| Transport & pilgrim services | 0 | 80 | 250 | 800 | 1,800 |
| Total net revenue | 1,019 | 5,098 | 10,967 | 22,420 | 40,244 |
EBITDA — three scenarios (SAR thousands)
| Year | Conservative | Base case | Optimistic |
|---|---|---|---|
| Year 1 | –558 | –62 | +1,805 |
| Year 2 | +789 | +3,312 | +12,123 |
| Year 3 | +3,655 | +8,590 | +13,995 |
| Year 5 | +17,997 | +36,744 | +54,130 |
Operating expenses — base case (SAR thousands)
| Line | Y1 | Y2 | Y3 | Y5 |
|---|---|---|---|---|
| Team | 350 | 600 | 1,050 | 2,200 |
| Technology & platform | 120 | 180 | 270 | 460 |
| Licensing & compliance | 80 | 60 | 80 | 100 |
| Indonesia operations | 100 | 130 | 180 | 270 |
| Overhead (office, travel, marketing) | 150 | 180 | 270 | 470 |
| Rate subsidy | 281 | 636 | 527 | 0 |
| Total OpEx | 1,081 | 1,786 | 2,377 | 3,500 |
Net income — base case (SAR thousands)
| Y1 | Y2 | Y3 | Y5 | |
|---|---|---|---|---|
| EBITDA | –62 | 3,312 | 8,590 | 36,744 |
| Interest income (settlement float) | +100 | +100 | +100 | +100 |
| CIT at 20% | 0 | –682 | –1,738 | –7,369 |
| Net income | 38 | 2,730 | 6,952 | 29,475 |
Monthly breakeven
| Scenario | Monthly OpEx | Agents needed | Month reached |
|---|---|---|---|
| Operating breakeven (ex-subsidy) | SAR 58K | 9 agents | Month 5–6 |
| Operating breakeven (incl. subsidy) | SAR 81K | 18 agents | Month 8–9 |
Use of funds
Capital efficiency summary
| Category | SAR | % | Nature |
|---|---|---|---|
| Recoverable working capital | 2,610,000 | 52% | Balance sheet asset — returned in wind-down |
| Permanent capital (Jeddah Bali) | 750,000 | 15% | Real asset with resale value |
| Operating expenses (24 months) | 1,640,000 | 33% | P&L expense — 24-month runway |
The SAR 5M raise is not a 24-month burn fund. 52% sits in recoverable assets on Day 1. The Jeddah Bali is a permanent asset with a 28–36 month payback. Operating expenses are only 33% of the raise.
Deal structure and investor terms
The raise
| Term | Detail |
|---|---|
| Raise size | SAR 5,000,000 |
| Instrument | Equity quotas (حصص) in PUAS LLC |
| Pre-money valuation | SAR 15,000,000 |
| Post-money valuation | SAR 20,000,000 |
| Investor equity | 25% of PUAS LLC |
| Founder equity | 75% of PUAS LLC |
| First close | SAR 2M minimum — operations begin |
| Final close | Remaining SAR 3M within 12 months of first close |
Pre-money valuation rationale
Three anchors justify SAR 15 million: (1) replacement cost — founder deployed SAR 750K of personal capital plus 2+ years of regulatory navigation that cannot be replicated at any price by a new entrant; (2) forward DCF — Year 3 base enterprise value SAR 38.5M discounted at 50% risk-adjusted rate = SAR 11.4M; Year 5 = SAR 21.2M; SAR 15M sits inside this range; (3) investor returns remain strong at the ask price.
Investor tranches
| Tranche | Who | Minimum ticket | Vehicle | Allocation target |
|---|---|---|---|---|
| Tranche A | Financial investors | SAR 500,000 | Direct PUAS quota holder | SAR 3–3.5M (60–70%) |
| Tranche B | Founding agent partners (PPIU owners) | SAR 100,000 | Single SPV | SAR 1.5–2M (30–40%) |
Cash return structure
Preferred distribution: 8% per annum cumulative, non-compounding, accruing from date of investment. On SAR 5M total: SAR 400,000 per year. Year 1 accrues. Year 2 onward: paid before any ordinary distribution. Unpaid amounts carry forward.
Ordinary distribution: After preferred return is covered, 30% of remaining net income distributed pro-rata to all quota holders.
Year 2 base case illustration: Net income SAR 2.73M − preferred return SAR 400K = SAR 2.33M × 30% = SAR 699K distributed. Total investor payout: SAR 1.1M (~22% cash-on-cash on SAR 5M invested).
Distribution waterfall (priority order)
- Settlement float maintained at SAR 2M minimum (untouchable)
- Accrued 8% preferred return paid to all investors
- 30% of remaining net income distributed pro-rata
- Remainder retained for working capital growth and Bali expansion
Governance
| Right | Detail |
|---|---|
| Observer seat | Any investor in the round |
| Board of Managers seat | Any single investor at SAR 2M+ |
| Management accounts | Quarterly — shared with all investors |
| Audited financials | Annual |
Reserved matters requiring investor consent: issuing new equity; amending profit distribution waterfall; selling assets above SAR 1M; related-party transactions above SAR 250K; debt exceeding SAR 2M; material change of business activity.
Exit pathways
| Path | Terms |
|---|---|
| Year 3 put option | Any investor may require founder to buy back at a total cash return (distributions + buyback) of 1.5× original invested capital. Founder has 90 days to settle. |
| Year 5 — Formula exit | Founder buyback at 3× Year 5 net revenue attributed to investor's equity stake |
| Year 5 — M&A | Strategic sale; investors participate pro-rata |
| Year 5 — Continued dividends | No exit; investors keep receiving distributions indefinitely |
Founding agent partner benefits (Tranche B only)
In addition to the same equity economics as Tranche A: priority allotment of hotel room blocks before the general agent pool; rate lock for 3 years (no worse than ActionPay's prevailing rate); referral commission of 15–20% of PUAS's hotel margin on volume brought by agents they refer, paid quarterly.
Tax disclosures
| Item | Rate | Note |
|---|---|---|
| Corporate income tax | 20% on foreign-owned portion | Modelled and confirmed |
| WHT on distributions — Indonesian investors | 5% | No Saudi-Indonesia double tax treaty |
| WHT on distributions — Saudi investors | 0% (resident) | Standard domestic treatment |
Returns and downside protection
Return scenarios — 25% equity stake
| Scenario | Year 3 exit | Year 5 MOIC | Year 5 IRR |
|---|---|---|---|
| Conservative (150 agents) | 0.97× exit + distributions | 3.1× | 25% |
| Base case (220 agents) | 1.9× exit + distributions | 8.0× | 51% |
| Optimistic (300+ agents) | 3.3× exit + distributions | 13.1× | 67% |
Year 3 weakness in conservative and base cases is addressed by: (a) 8% preferred return accruing from Day 1, (b) 30% dividend distribution from Year 2, and (c) 1.5× total-return put option.
Downside protection — wind-down scenario
| Asset | Recoverable SAR |
|---|---|
| Settlement float | 2,000,000 |
| Hotel deposits (partial) | 350,000–500,000 |
| MoT bank guarantee | 50,000 |
| Jeddah Bali fitout (resale) | 350,000–550,000 |
| Floor recovery | ~SAR 2.75–3.1M of SAR 5M |
Floor recovery of 55–62% is exceptional for seed-stage. Most seed investments offer no floor recovery. Here, 52% of the raise sits in recoverable balance sheet assets on Day 1.
Risk factors
| # | Risk | Severity | Mitigation |
|---|---|---|---|
| 1 | SAMA regulatory interpretation — exemptions not yet litigated | Medium | Three explicit exemptions; Saudi corporate legal opinion to be obtained |
| 2 | Indonesian Umrah law — Pasal 94(d) licence ambiguity | Medium | Indonesian counsel opinion being obtained; alternative compliance structures exist |
| 3 | Agent ramp risk — slower than modelled | Medium | Conservative case (15 agents Y1) covered by operating reserve; founding agent partner tranche aligns incentives |
| 4 | Hotel margin below modelled (Year 1) | Low | B2B platforms provide confirmed entry floor; direct hotel negotiation is execution, not regulatory |
| 5 | Working capital requirement exceeds model | Low | Aggressive ramp is a good problem; Kafalah facility from Year 2 pending eligibility confirmation |
| 6 | UU 14/2025 — individual Umrah reduces PPIU channel | Low | PPIU base of 2,600 active agents unaffected near-term; PUAS function relevant across booking channels |
| 7 | Founder dependency | Low | Team-building from Year 1; governance rights give investors meaningful oversight |
| 8 | 5% WHT on distributions to Indonesian investors | Low | Disclosed in all documentation; modelled into return projections |
The founder
Albaq Novfri Andrian
Founder and Managing Director, PUAS LLC. Based in Al-Khobar, Saudi Arabia.
Albaq has lived and worked in Saudi Arabia for more than 25 years. He holds a Premium Residence Iqama. He is an Indonesian national — shareholder agreements signed in Indonesia are enforceable under Indonesian law, a material benefit for Indonesian co-investors. His background is in industrial optimisation and large-scale operations in Saudi Arabia's petrochemical sector.
"This is not a pitch from someone who wants to enter Saudi Arabia. This is a pitch from someone who is already inside it."
Personal capital already deployed
| Item | SAR deployed | Status |
|---|---|---|
| PPIU licence — Indonesia | 150,000 | Held & active |
| The Bali Restaurant — Al-Khobar | 400,000 | Open |
| PUAS legal & licences — KSA | 200,000 | MISA + CR held |
| Total | 750,000 |
Investors are not being asked to fund the start of something. They are being asked to scale something that already exists. The legal foundation is laid. The first restaurant is open. The PPIU licence is held.
Open items before close
| # | Item | Owner | Priority |
|---|---|---|---|
| 1 | Indonesian counsel legal opinion — Pasal 94(d) MoT licence vs. MoH&U licence | Founder | High |
| 2 | MoT National Travel Agency licence — file and obtain | Founder | High |
| 3 | Written rate quote from ActionPay (SAR 100K transfer) | Founder | High |
| 4 | MaqamUmrah and WebBeds B2B pricing at PPIU volumes | Founder | High |
| 5 | Saudi corporate lawyer — Article 23 AoA preferred distribution opinion | Founder + counsel | High |
| 6 | Kafalah eligibility — SABB Kafalah desk | Founder | High |
| 7 | Founder Tax Residency Certificate (ZATCA) | Founder | Medium |
| 8 | Jeddah Bali site and rent estimate | Founder | Medium |
| 9 | 1–2 anchor hotel rate quotes (Accor / Elaf) | Founder | Medium |
| 10 | Nusuk Masar wholesale pricing to PPIU agents | Founder | Medium |
| 11 | Draft shareholders' agreement term sheet | Saudi counsel | Medium |
| 12 | SPV structure — draft agent SPV articles | Saudi counsel | Medium |
| 13 | Confirm no Saudi-Indonesia DTT signed since May 2026 | Counsel | Low |
Next steps
For investors
- Review this memorandum and the accompanying financial model in full
- Request the full financial model — 5-year projection with monthly Year 1–2 cash flow, sensitivity tables, and scenario detail
- Meet the founder — Albaq Andrian conducts investor meetings in Al-Khobar or by video call
- Legal and tax review — investors are encouraged to have their own advisors review the deal structure; a draft shareholders' agreement will be provided on request
- First close — minimum SAR 2M to open operations; first-close investors begin accruing the 8% preferred return immediately