⚠️ Legal Framework
Bahrain's AML framework is governed by Law No. 4 of 2001 (amended) and CBB Module FC (Financial Crime). All financial institutions, DNFBPs, and certain non-financial businesses must maintain AML programs.
Key Requirements
🔍 Customer Due Diligence (CDD)
Identity verification for all clients. Enhanced CDD for high-risk customers, PEPs, and complex structures. Ongoing monitoring of business relationships.
📋 UBO Declaration
All companies must declare Ultimate Beneficial Owners (25%+ ownership). UBO register maintained by MOICT. Annual confirmation required at CR renewal.
🚨 Suspicious Transaction Reporting
Report suspicious transactions to the Financial Intelligence Directorate (FID). No minimum threshold. Tipping off the subject is a criminal offence.
📚 Record Keeping
Maintain CDD records for 5 years after business relationship ends. Transaction records for 5 years from completion. Must be available to CBB on request.
👤 MLRO Appointment
Appoint MLRO (Money Laundering Reporting Officer) at board level. Annual AML training for all staff. Independent AML audit every 2 years.