The Man Behind a Decade of Saudi Arabia’s International Investment Decisions
Billions Deployed, Companies Rescued, Goodwill Written Off — and a Question Saudi Arabia Has the Right to Ask: Who Was Responsible for What?
For nearly a decade, one executive has occupied an unusually important position inside Saudi Arabia’s expanding global investment machine.
His name is Turqi Abdulrahman Alnowaiser.
He is not merely an adviser watching investments from Riyadh.
The Public Investment Fund describes Alnowaiser as the official responsible for leading its international investment strategy across public markets, private markets, real estate and infrastructure. He has led International Investments since 2016 and has served as Deputy Governor and Head of the International Investments Division since 2021. He is also a member of key PIF committees, including the Management Committee, Investment Management Committee and Portfolio Companies Nomination Committee. (https://annualreport.pif.gov.sa/en/who-we-are/our-leadership/?utm_source=chatgpt.com)
PIF’s own governance description says Executive Management and its committees evaluate investment and non-investment proposals before matters requiring higher approval are submitted to the Board or its committees, while certain powers are delegated to management committees. (https://www.pif.gov.sa/en/who-we-are/our-leadership/?utm_source=chatgpt.com)
That distinction is crucial.
This investigation does not claim that Turqi Alnowaiser personally approved every international investment made by PIF since 2016.
The public record does not support such a conclusion.
Instead, this investigation asks a narrower and potentially more consequential question:
What can the public record establish about Alnowaiser’s actual authority, documented participation and responsibility in international investments that later required billions of dollars of additional capital, suffered severe impairments, collapsed, or generated serious questions about valuation and governance?
The answer is not the same for every investment.
In some cases, Alnowaiser merely headed the division under which an investment sat.
In others, his name appears personally on regulatory filings.
In still others, he served on the portfolio company’s board.
And in Lucid, the documentary trail goes considerably further: he became chairman of the company while simultaneously exercising documented authority within the PIF-controlled investment vehicle that owns the Saudi stake.
That distinction forms the backbone of this investigation.
I. THE RISE OF TURQI ALNOWAISER
Alnowaiser’s career before PIF included positions at the Saudi Industrial Development Fund, Saudi Arabia’s Capital Market Authority, Morgan Stanley and Saudi Fransi Capital.
PIF says he joined the Fund as Senior Advisor in 2015 before becoming Head of International Investments in 2016. In June 2021 he became Deputy Governor while retaining responsibility for International Investments. (https://annualreport.pif.gov.sa/en/who-we-are/our-leadership/?utm_source=chatgpt.com)
His authority expanded during the same period in which PIF transformed itself into one of the world’s most aggressive sovereign investors.
The timing matters.
In October 2016, the same month Alnowaiser began leading International Investments, PIF and SoftBank announced plans for what became the SoftBank Vision Fund.
The initial memorandum contemplated as much as $45 billion from PIF over five years.
In May 2017 the commitment became binding: PIF would invest up to $45 billion in Vision Fund I. (https://www.pif.gov.sa/en/news-and-insights/press-releases/2016/softbank-group-corp/?utm_source=chatgpt.com)
The public record available for this investigation does not establish that Alnowaiser personally approved the $45 billion commitment.
It does establish that one of the largest international technology-investment commitments in Saudi history emerged just as he assumed leadership of PIF’s international investment operation.
That raises a basic accountability question:
What role did Alnowaiser play in evaluating, recommending, negotiating or monitoring PIF’s commitment to SoftBank Vision Fund I?
The answer should not be inferred.
PIF should disclose it.
II. AUTHORITY DOES NOT MEAN UNILATERAL CONTROL
An investigation into Alnowaiser must distinguish responsibility from absolute authority.
A 2021 Lucid SEC filing provides an unusually useful window into the PIF governance structure.
At that point, Yasir Al-Rumayyan was the sole manager of Ayar Third Investment Company, the PIF vehicle holding the Lucid investment. But Alnowaiser had delegated authority to vote Ayar’s securities subject to prior approval by one of PIF’s board committees. (https://www.sec.gov/Archives/edgar/data/1811210/000092963821000927/sc13d.htm?utm_source=chatgpt.com)
Later disclosures show an evolution.
By subsequent filings, Alnowaiser and PIF CFO Yasir Al-Salman were described as co-managers of Ayar, with authority to vote securities held by the vehicle. (https://www.sec.gov/Archives/edgar/data/1811210/000110465923115290/tm2329838-1_s3.htm?utm_source=chatgpt.com)
That means the evidence supports neither of two simplistic narratives.
It does not support saying:
“Alnowaiser personally controlled all PIF investment decisions.”
But it also does not support portraying him as an executive detached from those investments.
He occupied documented positions inside the investment, voting and portfolio-governance machinery.
The unanswered question is where recommendation ended and final approval began.
PIF has not publicly disclosed, in the material reviewed for this investigation, a transaction-by-transaction delegation matrix identifying exactly which official or committee approved each of the investments examined below.
That document — if it exists — could answer much of this investigation.
III. LUCID: THE STRONGEST DOCUMENTARY CONNECTION
No investment examined in this investigation connects Turqi Alnowaiser personally to PIF’s investment machinery as strongly as Lucid.
PIF announced its original Lucid investment in 2018.
Alnowaiser joined Lucid’s board in April 2019.
In April 2023, he became chairman. (https://www.sec.gov/Archives/edgar/data/1811210/000162828026026842/lcid-20260423.htm?utm_source=chatgpt.com)
But the relationship extends beyond a board seat.
Ayar Third Investment Company is the PIF-controlled vehicle through which much of the Saudi ownership of Lucid is held.
SEC disclosures establish that Alnowaiser has exercised formal authority connected with Ayar’s Lucid securities.
In 2021, his voting authority was delegated subject to prior PIF committee approval. (https://www.sec.gov/Archives/edgar/data/1811210/000092963821000927/sc13d.htm?utm_source=chatgpt.com)
Later disclosures identify Alnowaiser and Al-Salman as Ayar’s co-managers.
An April 2026 SEC filing states that they have authority to vote Ayar’s securities. It expressly says neither man has a personal pecuniary interest in Ayar’s shares. (https://www.sec.gov/Archives/edgar/data/1811210/000110465926053223/xslSCHEDULE_13D_X02/primary_doc.xml?utm_source=chatgpt.com)
Another April 2026 Form 4 goes further: it carries the signature:
Ayar Third Investment Company — /s/ Turqi A. Alnowaiser — Co-Manager.
The same filing explains that PIF may be considered a director “by deputization” because Alnowaiser, a PIF employee, represents Ayar on Lucid’s board. (https://www.sec.gov/Archives/edgar/data/1811210/000110465926053234/xslF345X06/tm2612717-1_4seq1.xml?utm_source=chatgpt.com)
That is a powerful piece of evidence.
It does not prove that Alnowaiser personally originated every investment.
It proves something narrower:
he was part of the formal control architecture of the PIF vehicle holding the investment while simultaneously chairing the company receiving Saudi capital.
IV. THE MONEY KEPT COMING
Lucid’s SEC disclosures show repeated capital injections from Ayar.
In May/June 2023, Ayar purchased shares providing approximately $1.8 billion in net proceeds to Lucid. (https://www.sec.gov/Archives/edgar/data/1811210/000110465924051463/tm2333393d2_def14a.htm?utm_source=chatgpt.com)
In March 2024, Ayar agreed to purchase Series A convertible preferred stock for:
$1 billion.
Lucid received approximately $997.6 million after issuance costs. (https://www.sec.gov/Archives/edgar/data/1811210/000110465924041218/tm2410184d1_8k.htm?utm_source=chatgpt.com)
Then came August 2024.
Ayar agreed to purchase Series B convertible preferred stock for another:
$750 million. (https://www.sec.gov/Archives/edgar/data/1811210/000162828024034724/lcid-20240804.htm?utm_source=chatgpt.com)
But the same announcement contained another potentially much larger exposure.
Ayar also agreed to provide Lucid with an unsecured delayed-draw term-loan facility of $750 million. (https://www.sec.gov/Archives/edgar/data/1811210/000162828024034724/lcid-20240804.htm?utm_source=chatgpt.com)
Then the facility expanded.
On November 4, 2025, Lucid and Ayar amended the credit agreement, increasing the delayed-draw commitment from $750 million to approximately:
$2 billion.
Lucid was also required to pay Ayar an upfront fee equal to 0.75% of the incremental commitment above $750 million, plus a quarterly 0.50% annualized fee on unused commitments. At the time of that filing, Lucid had not yet drawn the facility. (https://www.sec.gov/Archives/edgar/data/1811210/000162828025049553/lcid-20251104.htm?utm_source=chatgpt.com)
That distinction matters.
A credit commitment is not the same thing as cash already lost.
But it is additional financial exposure.
V. THE $430 MILLION CITIBANK TRANSACTION
In April 2025, another unusual transaction appeared.
Ayar entered into a privately negotiated prepaid-forward share purchase transaction with Citibank.
Ayar agreed to pay:
$430,000,000.80
for future delivery of:
179,166,667 Lucid shares. (https://www.sec.gov/Archives/edgar/data/1811210/000110465925033830/xslSCHEDULE_13D_X01/primary_doc.xml?utm_source=chatgpt.com)
The transaction was linked to Lucid’s $1.1 billion convertible-note issuance.
Again, the important issue for this investigation is not merely that PIF invested.
It is that Alnowaiser was documented as a co-manager of the investment vehicle controlling the securities.
VI. THEN ANOTHER $550 MILLION
In April 2026, Ayar acquired $550 million of Series C convertible preferred stock in Lucid.
The related SEC filing identifies PIF, Ayar, Turqi Alnowaiser and Yasir Al-Salman as reporting persons.
It states that Alnowaiser and Al-Salman, as co-managers, possess authority to vote the securities held by Ayar. (https://www.sec.gov/Archives/edgar/data/1811210/000110465926053223/xslSCHEDULE_13D_X02/primary_doc.xml?utm_source=chatgpt.com)
This creates an unavoidable governance question.
Alnowaiser was simultaneously:
Chairman of Lucid.
Deputy Governor and Head of International Investments at PIF.
Co-manager of Ayar.
Representative of Ayar on Lucid’s board.
None of those facts proves misconduct.
But together they create a legitimate need for transparency around related-party governance.
Who negotiated for Lucid?
Who negotiated for Ayar?
Did Alnowaiser participate on either side?
Did he recuse himself from Lucid board deliberations concerning capital supplied by the entity he represented?
Was an independent committee established?
Was a fairness opinion obtained?
Who determined that the terms were in Lucid’s interests?
Those questions should be answered with documents, not assumptions.
VII. THE ECONOMIC CONTEXT: LUCID’S LOSSES
The repeated capital injections occurred against a severe financial backdrop.
Lucid’s 2025 annual report says the company incurred net losses of approximately:
$2.8 billion in 2023
$2.7 billion in 2024
$2.7 billion in 2025.
By December 31, 2025, accumulated deficit had reached:
$15.6 billion. (https://www.sec.gov/Archives/edgar/data/1811210/000162828026011053/lcid-20251231.htm?utm_source=chatgpt.com)
By March 31, 2026, accumulated deficit had risen to approximately:
$16.6 billion, after another quarterly net loss of roughly $1.03 billion. (https://www.sec.gov/Archives/edgar/data/1811210/000162828026030517/lcid-20260331.htm?utm_source=chatgpt.com)
These are Lucid’s losses, not automatically PIF’s realized losses.
That distinction is essential.
But they establish the financial environment in which PIF-controlled Ayar continued providing capital.
For Saudi citizens, the accountability question is therefore straightforward:
At each successive funding round, what valuation, probability-weighted return and downside scenario justified increasing exposure?
And:
What would have happened to the value of the existing Saudi investment if PIF had refused to supply additional capital?
Those investment memoranda have not been made public.
VIII. PERSONAL COMPENSATION FROM LUCID
There is another issue that must remain separate from PIF’s ownership.
Alnowaiser receives compensation for serving on Lucid’s board.
Lucid’s 2026 proxy reports that his 2025 director compensation totaled:
$335,312
consisting of:
$90,000 cash
and
$245,312 in stock awards. (https://www.sec.gov/Archives/edgar/data/1811210/000162828026026949/lucid2026annualproxystat.htm?utm_source=chatgpt.com)
SEC filings also show personally held Lucid securities associated with his board service.
At the same time, SEC filings explicitly state that he has no personal pecuniary interest in the enormous block of Lucid shares owned by Ayar. (https://www.sec.gov/Archives/edgar/data/1811210/000162828026041612/xslF345X06/wk-form4_1780950532.xml?utm_source=chatgpt.com)
These are different pools of shares.
The investigation found no evidence that Ayar’s shares personally belong to Alnowaiser.
The question is instead:
Does PIF permit executives representing it on portfolio-company boards to retain personally the cash and equity compensation paid by those companies?
If yes, PIF should publish the policy.
If such compensation must instead be remitted to PIF, it should disclose that as well.
IX. MAGIC LEAP: FROM $400 MILLION TO A SAR 2.74 BILLION GOODWILL WRITE-OFF
Magic Leap presents a different problem.
PIF announced in March 2018 that it had invested:
$400 million
in Magic Leap’s Series D round.
PIF explicitly described the transaction as part of its International Investments portfolio. (https://www.pif.gov.sa/en/news-and-insights/press-releases/2018/pif-invests-400-million-dollar/?utm_source=chatgpt.com)
Alnowaiser had been leading International Investments since 2016.
That establishes organizational responsibility.
It does not establish that he personally approved the investment.
But the story becomes considerably more troubling when the subsequent accounting is examined.
PIF’s 2023 consolidated financial statements disclose Magic Leap goodwill and explain the impairment model used to support it.
The valuation used a five-year forecast.
Beyond year five, PIF applied an H-model that began with growth of:
90.20% in year five
and declined over ten years to:
1.8%.
The discount rate was:
53%–56%.
The financial statements say the 90.20% growth figure was projected by management.
After performing the analysis, management concluded that no impairment of Magic Leap goodwill was required in 2023. (https://www.pif.gov.sa/-/media/project/pif-corporate/pif-corporate-site/our-financials/financial-statements/pdfs/consolidated-financial-statements-2023.pdf?utm_source=chatgpt.com)
Then something changed dramatically.
PIF’s 2024 accounts show Magic Leap ownership at approximately:
59.09%
compared with 59.10% the previous year. (https://www.pif.gov.sa/-/media/project/pif-corporate/pif-corporate-site/our-financials/financial-statements/pdfs/consolidated-financial-statements-2024.pdf?utm_source=chatgpt.com)
The investment had not simply been sold.
Yet the SAR 2.740 billion of Magic Leap goodwill was impaired during 2024.
In other words, within one reporting cycle the goodwill moved from surviving PIF’s impairment analysis to being fully written down.
That is not proof of corruption.
It is an enormous valuation question.
What happened?
What forecast failed?
Who produced the 90.20% year-five growth assumption?
Was it Magic Leap management?
PIF management?
An external valuation adviser?
Who challenged it?
What actual 2024 performance differed from the 2023 forecast?
Why did the 2023 sensitivity analysis fail to anticipate a scenario that materialized quickly enough to result in a complete goodwill impairment the following year?
Saudi citizens should not have to guess.
The relevant documents are straightforward:
the 2023 Magic Leap impairment model and the 2024 impairment memorandum.
PIF should disclose who prepared, reviewed and approved them.
X. THE ALBLEHED CONNECTION
Magic Leap also exposes another part of PIF’s portfolio-governance structure.
Mohannad AlBlehed served within PIF and became Senior Director, Head of International Direct Investments in January 2019.
Babylon’s SEC filings identify him as a director of Magic Leap as well. (https://www.sec.gov/Archives/edgar/data/1866390/000110465922063468/bbln-20220331xf4.htm?utm_source=chatgpt.com)
This matters because Alnowaiser headed the broader International Investments division while AlBlehed headed International Direct Investments.
The public record reviewed here does not establish that AlBlehed reported directly to Alnowaiser, and this investigation will not claim that without an organizational chart or equivalent evidence.
But the two positions clearly occupied related layers of PIF’s international investment organization.
What reports did PIF-appointed directors provide to International Investments?
What portfolio-monitoring information reached Alnowaiser?
What information barriers existed between portfolio-company directors and PIF investment professionals?
These questions become particularly important because AlBlehed also sat on another company that ended far worse.
Babylon Health.
XI. BABYLON: CAPITAL ADDED BEFORE EQUITY WAS WIPED OUT
PIF participated in Babylon’s 2019 Series C financing.
Babylon’s filings show that the company sold Series C shares to investors including PIF, Kinnevik and VNV for an aggregate:
$320.3 million
while additional convertible notes held by Kinnevik and VNV were converted.
The $320.3 million therefore cannot simply be described as PIF’s investment amount. (https://www.sec.gov/Archives/edgar/data/1866390/000186639022000013/bbln-20211231.htm?utm_source=chatgpt.com)
AlBlehed joined Babylon’s board in December 2019.
By February 2022, PIF reported ownership of:
35,410,789 Babylon shares
representing approximately:
8.6%.
The SEC ownership filing was personally signed:
/s/ Turqi A. Alnowaiser
with his title:
Deputy Governor and Head of International Investments Division. (https://www.sec.gov/Archives/edgar/data/1767640/000110465922021832/tm226538-1_sc13g.htm?utm_source=chatgpt.com)
This signature proves Alnowaiser’s formal connection to PIF’s Babylon ownership disclosure.
It does not prove that he personally approved either the original investment or subsequent investments.
Then came November 2022.
Babylon raised approximately $80 million in a private placement.
PIF purchased:
1,614,358 shares
at:
$10.54 per share.
That represents approximately:
$17.0 million of additional PIF equity. (https://www.sec.gov/Archives/edgar/data/1866390/000186639023000055/bbln-20221231.htm?utm_source=chatgpt.com)
AlBlehed was still a Babylon director.
Months later, he left the board.
Then the situation deteriorated dramatically.
By June 2023, Babylon said a proposed restructuring would provide no payment to Class A shareholders or other equity holders, because AlbaCore would exercise rights under its debt agreements. (https://www.sec.gov/Archives/edgar/data/1866390/000186639023000105/bbln-20230623.htm?utm_source=chatgpt.com)
The proposed transaction later failed.
On August 7, 2023, Babylon said it had no binding commitment for additional financing sufficient to continue operations and warned that bankruptcy protection, administration or liquidation could follow.
It also said proceeds from any third-party sales were not expected to exceed indebtedness owed to AlbaCore and therefore were not expected to provide payment to Babylon’s ordinary shareholders or other equity holders. (https://www.sec.gov/Archives/edgar/data/1866390/000186639023000112/exhibit9917aug2023.htm?utm_source=chatgpt.com)
This produces one of the most important unanswered questions in this investigation:
What did PIF know in October–November 2022 when it committed another approximately $17 million of equity?
And specifically:
Who prepared the investment recommendation?
Who approved it?
Did Alnowaiser participate?
Did AlBlehed participate while simultaneously serving on Babylon’s board?
What information was available about cash burn, debt seniority, AlbaCore’s rights, future liquidity requirements and downside recovery for equity?
What conflict-management or recusal procedures were used?
The public record reviewed here does not establish that Alnowaiser personally signed the November 2022 subscription agreement.
That document should therefore be produced.
XII. THE PATTERN THAT REQUIRES AN ANSWER
Magic Leap and Babylon are not identical investments.
Lucid is different again.
But a pattern worth examining emerges:
A PIF international investment is made.
PIF obtains significant ownership.
A PIF executive or investment professional occupies a board position.
The company requires additional capital.
Additional Saudi-controlled capital is deployed.
The company remains financially challenged.
In Babylon, the equity eventually faced no expected recovery.
In Magic Leap, PIF subsequently recognized a SAR 2.740 billion goodwill impairment.
In Lucid, repeated financing continued while cumulative losses rose into the tens of billions of dollars.
This pattern does not establish corruption.
It does establish a legitimate question about portfolio discipline:
What conditions trigger PIF to stop funding an international portfolio company?
Does PIF operate predetermined loss limits?
Does it require independent re-underwriting after specified deterioration?
Who can override a recommendation to stop investing?
How are previous sunk costs prevented from influencing subsequent investment decisions?
Who signs the post-investment performance review?
And how many investments under International Investments have received additional funding after missing the assumptions contained in their original investment memorandum?
Those are questions that can be answered quantitatively.
XIII. MANARA MINERALS: $2.5 BILLION AND A CHAIRMAN
Another investment puts Alnowaiser in an even more explicit governance role.
He is Chairman of Manara Minerals.
Manara is a joint venture between PIF and Ma’aden.
In April 2024, Vale announced completion of the sale of a 10% stake in Vale Base Metals to Manara for approximately $2.5 billion. (https://www.vale.com/w/vale-announces-completion-of-strategic-partnership-agreement-with-manara-minerals-1?utm_source=chatgpt.com)
Unlike Babylon or Magic Leap, there is presently no basis in the evidence reviewed here to classify this investment as a failure.
But its scale and Alnowaiser’s chairmanship make it relevant to his investment record.
The questions are therefore forward-looking and governance-focused:
What valuation supported the $2.5 billion price?
What commodity-price assumptions were used?
Who performed financial and technical due diligence?
Which advisers were paid?
How much?
What governance rights did Manara receive?
What return has the investment generated to date?
Did Alnowaiser participate in Manara’s board approval?
Who signed the transaction documents for Manara?
Those answers would allow the public to compare a major minerals investment against the distressed technology investments examined above.
XIV. ELECTRONIC ARTS: THE NEXT GIANT BET
In September 2025, Electronic Arts announced an agreement to be acquired by a consortium comprising PIF, Silver Lake and Affinity Partners.
The announced enterprise value was approximately:
$55 billion. (https://www.pif.gov.sa/en/news-and-insights/newswire/2025/ea-announces-agreement-to-be-acquired-by-pif-silver-lake-and-affinity-partners-for-55-billion-usd/?utm_source=chatgpt.com)
That does not mean PIF invested $55 billion.
Enterprise value is not the same as PIF’s equity contribution.
The transaction closed in August 2026.
Alnowaiser spoke publicly for PIF both in connection with the transaction and after completion. PIF said it had already been a minority investor in EA for more than five years. (https://annualreport.pif.gov.sa/en/news-and-insights/newswire/2026/electronic-arts-announces-completion-of-acquisition-by-pif-silver-lake-and-affinity-partners/?utm_source=chatgpt.com)
But the public should be told something more useful than the headline transaction value.
How much equity did PIF commit?
How much came from Silver Lake?
How much came from Affinity?
How much acquisition debt was used?
What fees were paid?
What return assumptions justified the acquisition premium?
And who signed PIF’s equity commitment?
This investigation has not yet located a primary transaction signature page establishing that Alnowaiser personally signed PIF’s equity commitment.
Until such a document is found, it would be inaccurate to say he personally committed the money.
But given his position as Head of International Investments and PIF’s own decision to use him publicly as its voice on the transaction, his role in evaluating and recommending the deal is an obvious question requiring a direct answer.
XV. THE AFFINITY QUESTION
Affinity Partners’ participation deserves separate examination.
PIF is itself an investor in Affinity.
Affinity then became a consortium partner alongside PIF in the EA acquisition.
That fact alone proves no misconduct.
But it creates an important economic question:
How much of Affinity’s participation in EA is ultimately financed by capital previously committed to Affinity by PIF or other Saudi-linked investors?
If Saudi capital appears both through PIF’s direct consortium contribution and indirectly through a fund in which PIF is a major limited partner, the public deserves a clear calculation of Saudi economic exposure.
That is an accounting and transparency question, not an allegation.
XVI. NEWCASTLE AND NCUK: RESPONSIBILITY HAS A START DATE
The British corporate record allows another useful distinction.
Companies House shows that Alnowaiser became a director of NCUK Investment Limited on:
17 July 2023.
Yasir Al-Salman was appointed on the same date. (https://find-and-update.company-information.service.gov.uk/company/12415316/officers?utm_source=chatgpt.com)
That means the original 2021 Newcastle United acquisition should not be attributed to Alnowaiser merely because he later became an NCUK director.
But decisions made by NCUK after July 17, 2023 deserve examination.
These include subsequent capital injections, shareholder loans, ownership changes, acquisitions of additional interests and any material restructuring.
The correct question is not:
“Why did Alnowaiser buy Newcastle?”
The evidence does not establish that.
The correct questions are:
What NCUK decisions did he participate in after becoming a statutory director?
What additional capital was supplied?
What valuation was used when PIF’s effective ownership increased following the later ownership restructuring?
What loans exist between PIF and NCUK?
What distributions have returned to PIF?
And which NCUK financial statements or board resolutions were approved by Alnowaiser?
XVII. THE BRITISH SPV NETWORK
Alnowaiser also appears as a director in other British PIF investment vehicles, including entities such as PAUK and ABUK.
PIF’s 2024 consolidated financial statements list:
PAUK Investment Limited — 100% — Consumer Discretionary
RFUK Investment Limited — 100% — Consumer Discretionary
NCUK Investment Limited — 100% — Media and Entertainment
and Magic Leap at 59.09%. (https://www.pif.gov.sa/-/media/project/pif-corporate/pif-corporate-site/our-financials/financial-statements/pdfs/consolidated-financial-statements-2024.pdf?utm_source=chatgpt.com)
The names of these vehicles do not themselves establish the underlying investments.
This investigation will not guess.
Instead, the relevant accounts should be used to reconstruct:
PIF funding,
shareholder loans,
intercompany balances,
external borrowing,
interest,
acquisition cost,
impairments,
dividends,
related-party transactions,
and the underlying assets.
That exercise is particularly important for vehicles created or materially operated during Alnowaiser’s tenure as director.
XVIII. HEATHROW: A CONTROL CASE, NOT A FAILURE CASE
PIF completed its acquisition of approximately 15% of Heathrow Airport Holdings’ parent company in December 2024. (https://www.pif.gov.sa/en/news-and-insights/press-releases/2024/pif-completes-its-acquisition-of-15-stake-in-heathrow-airport/?utm_source=chatgpt.com)
On the same date, Alnowaiser became a non-executive shareholder director representing PIF.
Heathrow describes him as the executive who has led PIF’s International Investments division since 2016 and is responsible for developing and executing its global investment strategy. (https://www.heathrow.com/company/about-heathrow/company-information/leadership/the-board?utm_source=chatgpt.com)
Nothing in the material reviewed for this investigation justifies classifying Heathrow as a failed investment.
That is precisely why it belongs in the broader assessment.
An investigation should not select only failures.
Heathrow, Hapag-Lloyd and other investments can function as controls against which the governance of Babylon, Magic Leap and Lucid is compared.
XIX. HAPAG-LLOYD: ANOTHER CONTROL CASE — AND ANOTHER SOURCE OF PERSONAL COMPENSATION
PIF held approximately 10.2% of Hapag-Lloyd in 2018.
Alnowaiser was appointed to its Supervisory Board in February 2018 and formally elected by shareholders in July. (https://www.hapag-lloyd.com/content/dam/website/downloads/ir/HLAG_FY_2018_EN.pdf?utm_source=chatgpt.com)
He was also elected to Hapag-Lloyd’s Audit and Financial Committee in March 2018. (https://www.hapag-lloyd.com/content/dam/website/downloads/ir/HLAG_Group_Annual_Report_2018_AGM_2019.pdf?utm_source=chatgpt.com)
His disclosed Hapag-Lloyd remuneration for 2018 was:
€57,400. (https://static-cf.hapag-lloyd.com/content/dam/website/downloads/ir/HLAG_Management_Report_2018_AGM_2019.pdf?utm_source=chatgpt.com)
For both 2024 and 2025, Hapag-Lloyd reports annual remuneration of:
€126,000. (https://www.hapag-lloyd.com/content/dam/website/downloads/ir/HLAG_Remuneration_Report_2025.pdf?utm_source=chatgpt.com)
Again, these are disclosed board payments.
They are not evidence of bribery.
But they reinforce the unanswered PIF-policy question:
Does an executive appointed to represent Saudi sovereign investment interests personally retain portfolio-company director remuneration?
The policy should be public.
XX. UBER: WHERE THE DOCUMENTS PREVENT OVERSTATEMENT
Uber provides a useful example of why individual responsibility must be dated carefully.
Alnowaiser joined Uber’s board on:
16 November 2023
and joined its Audit Committee. (https://www.sec.gov/Archives/edgar/data/1543151/000155278123000451/e23460_uber-8k.htm?utm_source=chatgpt.com)
The original Saudi investment in Uber long predates that appointment.
More importantly, Alnowaiser’s initial SEC Form 3 says:
“No securities are beneficially owned.”
It further states that PIF’s Board exercises investment control over PIF’s Uber securities by majority vote. (https://www.sec.gov/Archives/edgar/data/1543151/000156218023007947/xslF345X02/primarydocument.xml?utm_source=chatgpt.com)
Therefore, the original Uber investment cannot responsibly be presented as an Alnowaiser decision on the basis of his later board membership.
His responsibility begins with the roles he actually held.
Uber also disclosed that he would participate in its non-employee director compensation program, including an annual cash retainer and restricted stock units. (https://www.sec.gov/Archives/edgar/data/1543151/000155278123000451/e23460_uber-8k.htm?utm_source=chatgpt.com)
Once again, that returns us to the same transparency question about retention or remittance of board compensation.
XXI. A DOCUMENTED RECORD — NOT GUILT BY ASSOCIATION
The evidence now permits a hierarchy of Alnowaiser’s connection to individual investments.
At the strongest end sits Lucid.
There, Alnowaiser is not merely Head of International Investments.
He has been a director since 2019.
He has been chairman since 2023.
He has exercised voting authority associated with Ayar.
He later became Ayar co-manager.
His signature appears on regulatory documents in that capacity.
And Ayar repeatedly supplied capital to Lucid while Lucid continued generating major losses. (https://www.sec.gov/Archives/edgar/data/1811210/000162828026026842/lcid-20260423.htm?utm_source=chatgpt.com)
Then comes Magic Leap.
The investment was explicitly part of International Investments; PIF ultimately controlled approximately 59%; a senior International Direct Investments executive sat on its board; and PIF subsequently recognized a SAR 2.740 billion goodwill impairment.
But a document proving Alnowaiser’s personal approval of the original or follow-on investments has not been established.
Then Babylon.
Alnowaiser personally signed PIF’s 2022 beneficial-ownership filing.
PIF subsequently invested approximately $17 million more in November 2022.
A senior PIF International Direct Investments executive sat on Babylon’s board.
Months later, the equity faced no expected recovery.
But Alnowaiser’s personal signature on the November 2022 subscription agreement has not been established.
Then Manara/Vale.
Alnowaiser chairs Manara, which invested approximately $2.5 billion for 10% of Vale Base Metals.
But the investment is not presently established as a failure.
Then EA.
The transaction is enormous and directly within PIF’s international-investment strategy, and Alnowaiser publicly represented PIF in discussing it.
But the investigation has not yet established his personal signature on PIF’s equity commitment.
That is how accountability should be constructed:
document by document, transaction by transaction, without substituting job title for evidence.
XXII. WHAT WE DID NOT FIND
A deep search for documented personal corruption allegations against Turqi Alnowaiser produced an important negative result.
This investigation has not identified a criminal judgment establishing that Alnowaiser accepted a bribe.
It has not identified a regulatory finding establishing that he received a kickback.
It has not identified credible documentary evidence of a sexual quid pro quo connected to investment decisions.
It has not identified evidence that PIF-owned Lucid shares personally belong to him; SEC filings expressly say the opposite.
Those allegations therefore should not be presented as facts.
But absence of evidence of bribery does not answer the investment-governance questions.
The relevant accountability issue is what happened to the money, who recommended additional exposure, what assumptions supported the decisions, who approved them, what information was available at the time, and what personal compensation portfolio-company representatives received.
XXIII. THE CENTRAL QUESTION FOR SAUDI ARABIA
Saudi Arabia’s international-investment program is routinely described in terms of scale.
Billions committed.
Global companies acquired.
Technology funded.
Sports purchased.
Airports acquired.
Mining stakes accumulated.
Gaming companies consolidated.
But scale is not performance.
And headline valuation is not return.
For citizens whose sovereign wealth is being deployed internationally, the meaningful questions are simpler:
How much cash went out?
How much came back?
What remains worth what PIF paid for it?
What was written down?
What failed?
What required rescue financing?
What fees were paid to fund managers, bankers, lawyers and advisers?
Who recommended each decision?
Who approved it?
Who was sitting on the portfolio-company board when conditions deteriorated?
Who decided to invest again?
And ultimately:
What is Turqi Alnowaiser’s measurable investment record after nearly a decade at the centre of PIF’s international-investment operation?
That number has not been publicly presented.
It should be.
XXIV. QUESTIONS FOR TURQI ALNOWAISER AND PIF
Before publication, Turqi Alnowaiser and the Public Investment Fund should be offered an opportunity to answer the following matters.
1. Please provide the total amount of capital deployed through PIF’s International Investments Division from October 2016 to the present, together with realized proceeds, distributions, current NAV, impairments and realized losses.
2. For Lucid, please identify Alnowaiser’s role in recommending, approving, negotiating or executing each original and follow-on investment.
3. For every Lucid financing involving Ayar while Alnowaiser served on Lucid’s board, did he participate in deliberations on both the investor and issuer sides?
4. Did he recuse himself from any Lucid board discussion concerning financing provided by Ayar or PIF?
5. Which independent Lucid directors or committees approved related transactions with Ayar?
6. Were fairness opinions or independent valuations obtained?
7. What return assumptions supported the repeated increases in Saudi exposure to Lucid despite continuing multi-billion-dollar losses?
8. What investment conditions would cause PIF to stop supplying additional capital to Lucid?
9. Does PIF consider any portion of its Lucid investment impaired?
10. What fees, interest, preferred returns or other consideration has Ayar received from Lucid?
11. For Magic Leap, who recommended PIF’s original $400 million investment?
12. Who approved subsequent funding?
13. Who prepared the 2023 Magic Leap impairment model?
14. Who approved the 90.20% year-five growth assumption?
15. Which external valuation specialists participated?
16. What changed between the 2023 assessment finding no goodwill impairment and the 2024 decision to impair SAR 2.740 billion of goodwill?
17. Please provide actual-versus-budget performance for Magic Leap for the relevant period.
18. What is PIF’s cumulative cash investment in Magic Leap, separate from the accounting value of goodwill?
19. For Babylon, who approved PIF’s approximately $17 million November 2022 follow-on investment?
20. Did Alnowaiser participate in that decision?
21. Did Mohannad AlBlehed participate while serving simultaneously as a Babylon director and senior PIF International Direct Investments executive?
22. What conflict-of-interest or recusal procedure applied?
23. What analysis did PIF perform concerning AlbaCore’s senior debt position before committing additional equity?
24. What recovery did PIF ultimately receive from its Babylon investment?
25. For Manara Minerals’ approximately $2.5 billion acquisition of 10% of Vale Base Metals, what valuation and commodity-price assumptions supported the transaction?
26. Did Alnowaiser participate in Manara’s board approval?
27. Who signed the transaction documents for Manara?
28. What fees were paid to financial, legal and technical advisers?
29. What is the current carrying value and return generated by the investment?
30. For the Electronic Arts acquisition, what was PIF’s exact equity contribution?
31. Who signed PIF’s equity commitment?
32. What acquisition debt was used?
33. What fees were paid?
34. What return assumptions supported the purchase price?
35. What portion, if any, of Affinity Partners’ EA investment was ultimately funded from capital committed to Affinity by PIF?
36. For NCUK, PAUK, ABUK and other international investment vehicles on whose boards Alnowaiser serves, please disclose shareholder loans, capital injections, external debt, impairments and distributions made during his directorship.
37. What authority was transferred to Alnowaiser and Yasir Al-Salman when they became directors of NCUK and PAUK in July 2023?
38. What is PIF’s formal policy governing employees appointed to portfolio-company boards?
39. May those employees personally retain board cash compensation?
40. May they personally retain restricted stock units or other equity awards?
41. If compensation must be remitted to PIF, has all compensation received by Alnowaiser from Lucid, Uber, Hapag-Lloyd and other PIF-related portfolio appointments been remitted?
42. What information may PIF-appointed portfolio directors legally provide to PIF investment teams?
43. What information barriers exist when a PIF employee is simultaneously a director of a listed portfolio company?
44. Please provide the applicable conflict-of-interest and related-party transaction policies.
45. Please identify the PIF governing body that approved each investment and follow-on financing discussed in this investigation.
46. For each transaction, did Alnowaiser vote, recommend approval, abstain or recuse himself?
47. What delegated-authority thresholds applied?
48. How many International Investments portfolio companies have required follow-on financing after materially missing their original business plan?
49. What cumulative impairments have been recorded against investments originated or managed by International Investments since Alnowaiser became its head?
50. Finally, what is the division’s complete realized and unrealized investment return since October 2016, net of management fees, external adviser fees, financing costs, impairments and write-offs?
CONCLUSION
This investigation does not need to invent a secret payment, a hidden conspiracy or a criminal allegation to raise serious questions.
The disclosed record is substantial enough.
Turqi Alnowaiser has spent nearly a decade at the centre of PIF’s international investment operation.
PIF itself says he leads its international investment strategy.
He sits on its major management and investment committees.
He has represented Saudi sovereign capital on foreign corporate boards.
He chairs Lucid.
He chairs Manara Minerals.
He has served on Hapag-Lloyd’s Supervisory Board and Audit and Financial Committee.
He sits on Uber’s board and Audit Committee.
He represents PIF at Heathrow.
He has exercised documented authority connected with Ayar, the PIF vehicle holding the Saudi Lucid stake.
And during this period, some international investments required repeated injections of capital, one healthcare investment collapsed with no expected payment to equity holders, and one major technology investment suffered a SAR 2.740 billion goodwill impairment only a year after management’s valuation model had supported no impairment.
Those facts do not answer every question.
They make the unanswered questions more important.
The fundamental issue is therefore not whether Turqi Alnowaiser can be blamed for every failed company in which Saudi Arabia invested.
The documents do not establish that.
The issue is whether Saudi Arabia can reconstruct, transaction by transaction, what he recommended, what he voted for, what he signed, what he inherited, what he attempted to rescue, what succeeded, what failed, how much additional capital was committed after warning signs emerged, and what return the Kingdom ultimately received.
For an investment operation deploying sovereign wealth on this scale, that should not be unknowable.
It should be auditable.
And it should be explainable to the public whose national wealth stands behind it.
