Reporting Indicators

1. The client does not show any interest in the transaction's amount or commission.
2. Understanding the reason why the client chose this bank to conduct his transactions.
3. An unexpected or frequent change of the actual beneficiary.
4. An unexpected or unjustified change of the bank.
5. An unexpected or frequent change to the method of contacting the client.
6. The client uses the same address; changes the names associated with him; refuses to receive any documents from the bank, or gives contact details that do not match the address.
7. The client provides false information or refrains from providing the information along with documents showing the business relationship, activity and source of funds.
8. The client evades or refuses the bank's application of the "Know Your Client" model.
9. The client is accompanied by people who do not have a clear role but show an influential role in shaping the business relationship.
10. The client requests freedom of action that goes beyond the usual scope.
11. A client, acknowledges, speaks of, or is known to be associated with criminal activities.
12. The client demonstrates strong curiosity regarding systems, control mechanisms, internal policies and monitoring.
13. The client is tense in a way unproportionate with the nature of the transaction.
14. The client attempts to build close relationships with the bank's employees.
15. The client uses aliases and a group of similar addresses.
16. The client offers money or rewards to secure services that appear suspicious.
17. The client is unemployed and often makes huge transactions or high account activity.
18. The client maintains high balances on his credit card.
19. The client is considered a foreign national who does not have regular business dealings in the Kingdom of Bahrain and who obtains professional or financial services.
20. The client is a politically exposed person or a prominent political figure or is associated with one.
21. The client performs transactions that do not match his age, and this is especially true for underage clients (minors).
22. The client conducts financial activities and transactions that do not fit the "Know Your Client" model.
23. The income disclosed by the client is not compatible with his assets, transactions, or lifestyle.
24. The client provides copies of his recent personal documents without the original documents, or they do not contain important details, such as the phone number, or he requests to be identified based on other than his personal documents.
25. The client was significantly late in submitting the company's documents.
26. Submitting all documents in a foreign language or they cannot be verified.
27. The client is uncooperative in identifying the actual beneficiary pursuant to Resolution No. (83) of 2020 regarding criteria, controls and rules for determining the ultimate beneficiary.
28. The client offers banknotes that are folded or wrapped in a way he never used to do before.
29. The client attempts to make transfers to another bank without providing all the details about the beneficiary.
30. Conducting multiple transactions on the same day at the same branch or different branches with a clear attempt to go to different employees.
31. The absence of clear relationships between the client and third parties in the transaction on the one hand, and the country in which the bank is located on the other hand.
32. The commercial relations with juridical entities are not included in the public records or official databases, and it is not possible to obtain official certificates about them.
33. Describing a juridical person as practicing a commercial activity, but this cannot be found on the Internet or social media sites, or the presence of persons authorized to sign the accounts of the juridical person without justification.
34. Registration of the juridical person under a name that does not indicate the actual activity, or indicates that the person carries out activities or services that are not available, or a name of a person similar to the name of another legal person.
35. Using an informal email address, such as Yahoo, Gmail, or Hotmail.
36. Registering a juridical person in an address that does not match its file, or under an address that cannot be identified on online mapping programs, or an address that has been used by many juridical persons.
37. The account has no balance despite the frequent incoming and outgoing transactions.
38. Limited knowledge of commercial activity despite the existence of interests among juridical persons.
39. Asking for the expedited implementation of transactions without concern for the risks or additional costs that may entail.
40. Asset sales are inflated between entities controlled by the same beneficiary.
41. The inclusion of family members who do not have any role or participation in running the business as beneficial owners of juridical persons or legal arrangements.
42. The resignation and replacement of the directors or the main shareholders shortly after the incorporation, or the frequent change of the work site without justification.
43. Complex institutional structures that legally do not require this level of complexity or do not have commercial sense.

1. The sudden return of activity to the account without any logical explanation (for example: large cash deposits are suddenly transferred abroad).
2. The financial transactions are illogical, and are incompatible with the client’s bank history and the goal of the business relationship, or do not match the client’s current situation.
3. A transaction appears outside the normal commercial practices framework of the concerned sector, or is economically feasible for the client, or is complex without justification.
4. The transactions related to a large project, whose main financing is secured by unidentified investors according to the client’s testimony. 
5. The client requests receipts for cash withdrawals or deliveries of securities that did not take place at all, or a request to implement payment orders with wrong details about the transfer party, or a request to transfer some payments through other accounts belonging to him and not from his personal accounts.
6. There are indications that the client has performed actions punishable by law in the Kingdom of Bahrain.
7. Excessive justification of the transaction or the exaggeration in providing documents proving its authenticity, or expressing his desire to send debit and credit cards to local addresses other than his address.
8. The client strangely visits his safety deposit box directly before making any cash deposits.
9. The client is registered to acquire and liquidate many assets quickly and without reason, or burdening them with various mortgages without an economic explanation.
10. The existence of transactions for a client who owns many licenses issued to his companies.
11. The client makes frequent cash transactions, or requests them to be executed in large amounts that are not consistent with transactions executed in the past.
12. The client uses banknotes in denominations that differ from what he preferred to deal with in the past, while the standards for cash dealings in the sector he works in are much larger or much smaller denominations.
13. The profession occupied by the client, according to what he reported, does not appear to be compatible with the level or type of activity, (for example: a student or an unemployed person who makes cash deposits / withdrawals in a number of branches in a large geographical area).
14. The client withdraws large sums of cash without making deposits in the same period, or depositing in the account of another person who is not associated with him.
15. The client requests to transfer an amount abroad without a clear logical reason.
16. Transactions that involve withdrawing assets shortly after being deposited, or have recurring deposits that are justified as proceeds from selling unknown assets.
17. Third parties deposit cash or checks into the client's credit card account.
18. The client does multiple fund transfers outside the country where he is the beneficiary.
19. The relationship between the transaction parties raises doubts whereby the client cannot find an adequate explanation for it.
20. The transaction is considered a commercial transaction that takes place between one or more parties from the same family without a clear economic justification.
21. One of the account’s authorized dealers executes the transactions with large or recurring amounts, but he does not own any stakes or assets in the company.
22. Exploiting the company’s account to carry out personal transactions such as financing personal purchases, including the purchase of assets or entertainment activities that are not compatible with the company’s profile.
23. Using many large cash payments to pay off a loan or mortgage ahead of time while bearing the loss, or buying high valued items in cash.
24. The client submits forged records or forges them.
25. Conducting a large number of transactions with a small number of beneficiaries, or a small number of high valued transactions with a small number of beneficiaries.
26. Conducting regular transactions with international companies without sufficient justification for the cooperation or trade with these companies.
27. The juridical person’s records show the absence of activity for a long period after its establishment, followed by a sudden and unexplained increase in financial activities.
28. The client has many accounts and deposits cash in each of them, amounting to a huge sum, or frequent transfers of large sums abroad.
29. Accepting transfers from other banks without knowing the transferor.
30. Depositing funds in multiple accounts that unite into one account and are transferred outside the country.

1. Opening accounts in the names of other people to use as an interface, or names very close to the names of commercial establishments, or false names.
2. The actual activity significantly exceeds the expected activity upon opening the account.
3. Executing the transaction from the company’s account using large amounts of cash, through either deposits or withdraws which is not compatible with the company's activity. The incoming and outgoing operations are similar in size and are sent to / received from the same accounts, indicating that the issued funds are returned with a partial loss.
4. Creating multiple accounts without a logical need for that, or accounts with a large number of deposits of small sums and few withdrawals of large sums.
5. Using loan facilities in a manner that may appear normal during international trade operations but is not compatible with the client's business activities.
6. The structure of the client's commercial relationship with banks is not economically logical.
7. Third parties that are not closely related to the client provide the guarantee
8. A large number of different people making different deposits in one account, or using the account for temporary deposits.
9. Using the name of another party to conduct commercial transactions for commercial or industrial projects.
10. Closing accounts and opening new accounts in the name of the client or in the name of other persons close to him, or the client requests opening multiple accounts without justification.
11. Cash deposits followed shortly by electronic transfers, particularly to high-risk countries.
12. The accumulation of huge assets that are incompatible with the commercial activity of the institution owned by the client, and transfers or loans to foreign companies or accounts outside the country.
13. Large deposits or transactions from a vague source provided that they are sent or guaranteed by an external bank (offshore).
14. Using guarantee letters and other means of commercial financing to transfer funds between countries while the commercial activity does not match that of the client.
15. The client purchases foreign currencies or other negotiable instruments through cash payment, while this appears uncommon to the normal activities of the client.
16. The client receives checks for large sums that is incompatible with the nature of his work, or exchanges a large amount of small banknotes denominations for large denominations.

Indicators Related to Geographical Location

1. Loans linked to commitments from external banks (offshore), with the difficulty of verifying the truth of these liabilities.
2. The transaction is related to a country known for its banking secrecy and weak legal frameworks for the work of companies, or it takes place in several countries without an economic or financial justification.
3. Transactions related to a country known for its high crime rate (such as: rampant corruption, terrorism, and massive drug production), or are considered high-risk countries in terms of money laundering or terrorist financing.
4. The client has accounts in different financial institutions in one geographical area without a clear economic need, or an account in a region other than the customer’s residence.

• Shell Companies

1. Informal owners, such as children, spouses, relatives or partners who do not appear to be involved in running the companies.
2. Not performing any actual commercial activities.
3. The absence of operating expenses (rents, salaries, value of goods) for the juridical person, employees, or one person as an employee.
4. Using the company’s account as a temporary deposit station, and to funnel funds in order to hide the actual beneficiary.

1. The client’s extreme secrecy regarding his identity / the true beneficiary's identity and the funding source.
2. The client hires an agent or intermediary without a convincing reason.
3. The client's refusal or reluctance to provide the data and documents required to execute the transaction, or submits false or forged documents.
4. The client occupies a public position, or has professional or family ties with a person who held a similar job, and they have an unusual special commercial relationship due to the frequency of joint transactions.
5. The client was convicted of a property crime, is currently under investigation for a property crime, or has ties to criminals.
6. The client or his partners are connected to terrorism or activities related to financing terror.
7. The client demonstrates an extraordinary familiarity with the normal standards stipulated in the law regarding determining the acceptable identity of the customer, entering data and reports of suspicious transactions – meaning that he asks repeatedly about the procedures of applying normal standards.
8. The inappropriateness of a natural person who acts as a director or representative to occupy this position.
9. A non-resident customer or the customer who does not have an address, has multiple addresses, or has a criminal record that includes fraud or breach of trust.
10. Companies with nominee shareholders or bearer shares.
11. The customer is from or in a country known to have insufficient measures to prevent money laundering and terror financing.
12. The customer is a commercial entity and cannot be found on the internet, and / or uses a public email address such as Hotmail, Gmail, Yahoo, etc.
13. The customer or a third party contributes a huge amount of cash as a guarantee provided by the borrower / debtor instead of using those funds directly, without a reasonable explanation.
14. The customer uses multiple bank accounts or foreign accounts without a valid reason.
15. The client has ties to a legal professional that is guiding him to carry out the transaction, or the transaction is lacking a legitimate or economic reason.
16. The customer is willing to pay fees higher than usual without a logical reason for that.
17. The client changes his advisor several times within a short period, or employs multiple legal advisors without a legal reason.

1. The parties or representatives of the transaction are citizens, residents, registered in a high-risk country, or interconnected without a clear commercial reason.
2. Ties between family members or parties at work or the company, or any other suspicious circumstances.
3. The frequent appearance of the same parties in the transactions during a short period, or the age of the parties carrying out the transaction is under the legal age, or are unqualified, without a logical explanation.
4. Attempts to hide the transaction’s true owner or parties.
5. The person actually managing the process is not an official party of the transaction nor a party representative.
6. Businesses that rely on the heavy use of cash.
7. Funding from a third party either for the transaction or to cover the associated fees / taxes without a clear link or legal explanation for that.
8. Another company, commercial establishment, or government finances special expenditures.
9. Postponing the choosing of the payment method to a date close to the time of registration in a country where the method of payment is usually guaranteed in the contract without a logical explanation.
10. Determining an unusually short repayment period, or repaying mortgage loans repeatedly and noticeably before the originally agreed upon maturity date without a reasonable explanation.
11. Buying assets with cash and then immediately using them as collateral for a loan.
12. A request to change the payment procedures previously agreed upon, or providing financing to a borrower who is either a natural or juridical person and not a credit institution, without a reasonable explanation.
13. The transaction includes an inconsistent amount of private funds, bearer checks or cash, especially if it is not consistent with the person’s socio-economic status or the company's economic position.
14. Refusing the requested service by one of the lawyers, or if the relationship with another lawyer has been severed.

1. The customer is from a country known to have insufficient measures to prevent money laundering and terrorist financing.
2. Funds that are received or sent to a foreign country without a clear link between the country and the client, or that are sent to high-risk countries.
3. The transaction’s guarantee is currently in a high-risk country.
4. Recording an increase in the capital from a foreign country that is unrelated to the company or in a high-risk country.
5. The company illogically receives very high support regarding capital or in-kind assets when compared to the company's business, size, or market.
6. Unjustifiable and excessive high or low price fluctuations associated with transferred securities (such as: volume of revenue, trade or business, headquarters, volume).
7. The existence of huge financial transactions requested by newly established companies when they are not justified with regards to the purpose of establishing the company. 
8. Making deposits to the legal representative’s account without the presence of actual transactions.
9. Organized cash deposits in the client's account under the legal limit, then withdrawing funds by transfers or bank check to the legal representative's trust account.

1. The client lives beyond his financial capabilities.
2. The client has a commercial activity not compatible with the averages recorded in this sector or with the financial ratios.
3. The client has checks that do not correspond with the volume of his sales (for example: unusual payments from unlikely sources).
4. The client has a history of changing accountants and account administrators annually.
5. The client does not know the whereabouts of the company records.
6. The company is incurring non-existing debts, or debts that have been paid but appear continuously in the current financial statements.
7. The company does not have employees, which is unusual in this type of activity.
8. The company pays unusual consultation fees to companies abroad, or the company’s records consistently reflect sales at less than the cost, which incurs losses to the company, and the company continues to provide illogical explanations for the losses.
9. There are discrepancies in the accounts supervised by the financial controller.
10. Failure to disclose the entire individual's income for the last tax year.
11. Seeking the help of many companies, corporate consultants and associated companies to audit the accounts.
12. The client takes a defensive stance when questioned, or over-justifies the deal, or recently establishes a series of new relationships with various financial entities, or provides money, gratuities, or an unusual preference for providing services that may appear unusual or suspicious.
13. The client attempts to convince the employee not to complete any documents required for the transaction, or has a history of changing billing accounts or accountants annually.
14. The client exchanges low denomination currencies for high ones.

1. The incompatibility of the loans provided by the shareholders with the company's commercial activity.
2. The presence of wrong data regarding commercial activity and the fact that they are not easily traced through the company's books.
3. The company paid huge sums to subsidiary companies or companies with similar control that do not fall within the company's normal commercial framework.
4. The company acquires personal and consumer assets (such as: boats, luxury cars, homes and private rural villas) while these transactions do not comply with the client's normal business practices or with the commercial activity of this particular sector.
5. The existence of unauthorized or improperly recorded transactions and insufficient audit trails, or structuring transactions in an orderly manner under the legal limit to avoid dealing with identification requirements, or maintaining regulatory records and reporting thresholds.
6. Completing transactions through intermediaries without an apparent reason, or the shareholders' loans do not correspond with the commercial activity.
7. The company makes large payments to subsidiaries or other entities within the group that do not appear in the normal course of business.
8. The permanent use of the personal bank account for commercial purposes, or opening a bank account that is used exclusively for depositing foreign currencies.

1. The company pays bills of organizations located in a country without adequate anti-money laundering laws and is known for its banking secrecy or as a safe tax haven.

1. The client completes the real estate transaction in exchange for a large amount of cash.
2. The client purchases the property in the name of a partner or relative.
3. The client is unwilling to place his name on any document that could link him with the ownership, or if he uses different names for the purchase offers, transaction documents, and deposit receipts.
4. Replacing the buyer's name at the last moment without justification.
5. The client negotiates a purchase that is equal to market value or greater than the offer price, but without a minimum value on the documents, and the difference is paid outside the framework of the transaction.
6. The client sells the property for less than market value, while providing an additional payment.
7. The client pays the initial deposit via check from a third party other than a spouse or a parent.
8. The client pays the advance payment in cash, and an unknown source or an external bank finances the balance.
9. The client buys real estate for personal use via the company, without this transaction being compatible with normal commercial activities, or buys real estate without inspecting it, or buys multiple properties within a short period.
10. The client pays rent allowance or rent in advance using large amounts of cash.
11. The client's extreme secrecy about the client, the actual owner, the source of the funds, and the reason for the transaction.
12. Using an agent or mediator without a convincing reason, or strongly rejecting any personal contact with him, or refusing to provide the information, data, and documents usually required when executing the transaction, or providing false or forged documents.
13. The client was convicted of a property crime, is currently being investigated for a property crime, or has ties to criminals.
14. The client is associated with a person involved or suspected of being involved in terrorism or activities related to financing terror, or if the client is personally involvement in that.
15. Unusual familiarity with the standards stipulated in the law that relate to determining acceptable client identity, data entry, and suspicious transaction reports.
16. Signs documents by fax only.
17. The buyer of income-generating real-estates does not show any interest in generating profit, whether by filling vacancies or by adjusting rent according to the market value.
18. Requiring the completion of the real estate purchase process in an expedited and unjustified manner.

1. The transaction involves newly formed juridical persons if the transaction's amount is large in comparison to the assets they own.
2. The transaction includes juridical entities unrelated to the transaction or the activity carried out by the company.
3. The transaction includes institutions, cultural or entertainment societies, or non-profit entities in general, and the characteristics of the transaction do not agree with the entity's objectives.
4. The transaction includes juridical persons with unknown addresses or barely any means of communication, such as: (post office box, shared office or shared business address, etc.), or the data provided is suspected of being wrong.
5. The existence of various transactions involving the same party, or transactions carried out between a group of juridical persons who may have ties such as family ties between owners or representatives or those with commercial ties all carry the same nationality such as the juridical person or its owners or representatives and share the same address, or the juridical persons or its owners or representatives have the same owner, representative, attorney or entities with similar names.
6. Creating juridical persons to manage real estate. The sole aim of the creation is to place a pseudo-person as a front between the property and the real owner.
7. The transaction shows signs or assurances that the parties do not act under their own names, if transactions begin under one name and end under another without a logical explanation for this change, if the transaction parties show no special interest in the property's characteristics such as: building quality or location, or if the parties show no interest in obtaining a better price for it, or where parties show interest in carrying out the transaction expeditiously without cause.
8. The transactions in which parties show great interest in certain areas without showing interest in the amount to pay, or in which the parties are foreigners or non-residents for tax purposes and their only goal is to invest capital, or in which the parties are foreigners or non-residents for tax purposes and are interested in large-scale operations (such as: buying large areas of land to build homes on), or in which a third party, other than the parties involved, makes any payments. Exceptions may be made in cases where payment is made by a credit institution registered in the country at the time of the signature on the transfer of ownership.
9. If the transaction's parties or representatives are citizens, residents, or registered in a high-risk country, or are interconnected without a clear commercial reason.
10. The emergence of the same parties in multiple transactions during a short period of time, or attempting to hide the real owner or parties in the transaction.
11. The person actually managing the process is not an official party of the transaction or their representative.
12. A natural person acting as a manager or a representative but does not appear to be a suitable one.
13. The transactions that take the form of a special contract and in which there is no intention to register the contract, or in which the intention was expressed but was not completed in the end, or in which it takes place without a clause in the contract that causes the buyer to lose the deposit in case the sale was not made.
14. The transactions that are related to the property itself or to the rights it entails at a rapid pace (such as: the purchase and immediate sale of the property), which include a significant increase or decrease in the price compared to the purchase price.
15. The transactions that are entered into for a completely different value (much higher or lower) than the actual property value, or in which it differs significantly from the market values.
16. The transactions that take place through intermediaries working on behalf of groups of people with potential ties (such as: family or business ties, or same nationalities).
17. The transactions that take place through intermediaries working on behalf of groups of juridical persons with potential ties (such as: family ties between owners or representatives or commercial ties).
18. Transactions involving cash payments or negotiable instruments that do not declare the actual payment party (such as bank transfers), and in which the accumulated amount is considered to be large when compared to the total amount of the transaction, or in which the party requests that the payment be divided into smaller installments with a short period of time between them.
19. Transactions with suspicions regarding the authenticity of the submitted documents with the loan application, or that are made in exchange for a loan by using a cash guarantee, or if this guarantee is deposited abroad.
20. The transactions in which payments are made in cash or via bank bonds, bearer checks, or other unknown instruments, and if checks are endorsed to a third party when payments are made.
21. The transactions involving funds from countries that are considered tax exempt or risky regions based on the law.
22. The transactions in which the buyer incurs a very large debt compared to the property's value.

1. The transactions involve juridical persons or legal arrangements registered in tax-exempt or risky areas.
2. The clients show great interest in purchasing properties in certain areas without concern about the price.
3. The real estate contributes to the capital of a company that does not have a registered address or a permanent headquarters open to the public in the country. 

1. The client purchases goods randomly regardless of their value, size, or color.
2. The purchase or sale operations are unusual for the client or the supplier (for example: the profession and age of the buyer does not match the value of the transaction or the type of precious stones or metals associated with the transaction).
3. The client or supplier attempts to maintain a high degree of confidentiality regarding the transaction, such as asking not to keep normal commercial records.
4. The client is reluctance to give accurate information about his identity when making a purchase, and then regains a large sum of money.
5. The client requests an item and pays for it in cash, and then cancels the order and regains a large sum of money, or asks about the possibility of returning the goods and obtaining a check in return, especially if the client requests writing the check in the name of a third party.
6. The client pays a high price in cash for a piece of jewelry or a precious metal without negotiating the price, or if the piece surpasses the client's ability compared to his profession or his declared or known income.
7. The client or supplier does not occupy a position in the company he claims to represent, or has reservations about disclosing his job.
8. The client changes his bank accounts frequently and illogically.
9. The client is a politically exposed person.
10. The client uses non-bank financial institutions without apparent reason or commercial interest.
11. An unknown client requests to convert gold into bullion.
12. The client owns several companies that trade gold and precious metals.
13. The continuous changing of commercial names for entities registered to deal in gold and precious metals.
14. The supplier suspiciously offers a low price or large discount to speed up transactions.

1. Using unusual amounts of cash to pay for the commodity.
2. The transaction lacks commercial sense.
3. Large and regular payments in a currency other than Bahraini Dinars.
4. Requesting to increase or reduce the value of the invoice, or requesting organized, complex or multiple invoices.
5. Very expensive shipments that are over-insured or undervalued.
6. The buyers or sellers lack acceptable experience in the precious metals and gemstones sector.
7. A large sum transaction from an unknown merchant.
8. Selling gold bars, coins and diamonds from a retail jewelry store.
9. Buying or selling operations that do not conform to standard business practices in the relevant sector.
10. The company’s cargo transfer process is unclear.

1. The presence of a store, branch, or partner affiliated to him in non-cooperative countries or regions, according to the FATF lists.
2. The client or supplier is associated with a high risk area.