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AML for Tax Advisors

Your AML obligations as a designated non-financial business.

COMPLIANCEMarch 2026 ยท 6 min read

Key Obligations

๐Ÿ” Customer Due Diligence

Identify and verify client identity before engagement. Understand the nature of client's business. Identify beneficial owners. Enhanced due diligence for PEPs and high-risk clients. Ongoing monitoring of business relationship.

๐Ÿšจ Suspicious Reporting

Report to Financial Intelligence Directorate (FID). No tipping off โ€” criminal offence. Internal reporting procedures required. MLRO (Money Laundering Reporting Officer) appointment mandatory for firms.

๐Ÿ“ Record Keeping

Maintain CDD documents for 5 years after relationship ends. Transaction records for 5 years. Staff training records. Risk assessment documentation. Available for inspection by MOIC.

๐Ÿ›๏ธ FATF Standards

Bahrain โ€” FATF Mutual Evaluation member. Recent enhancement of AML/CFT framework. Tax evasion is now a predicate offence. Accountants and tax advisors are DNFBPs (Designated Non-Financial Businesses and Professions).

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