THE KINGDOM OF BAHRAIN’S NATIONAL RISK ASSESSMENT 2025

16 Methodology 39. The World Bank tool (Legal Persons and Arrangements ML Risk Assessment Tool 2022) has been utilized to ensure comprehensive coverage of both entity-specific risks and broader ML threats from legal structures. It involved a structured approach that integrated the Legal Persons (LP) risk assessment with the National ML risk assessment. The approach used was a step-by-step integration process: − Mapping/identifying of Legal Structures (Step 1): Mapping out all types of legal persons and arrangements in the jurisdiction. This includes companies, trusts, partnerships, and other legal entities. Categorize Entities: Classify these entities based on their characteristics, ownership structures, and the sectors they operate in. − Threat Assessment (Money Laundering) (Step 2) − Entity Risk Assessment (Step 3) − National Vulnerability Assessment (Step 4) Basic & Beneficial Ownership Information 40. Information on the creation and types of legal persons, such as companies, is publicly available. It is stipulated in the Commercial Companies Law and in the Sijilat system, which is the online central register for companies in Bahrain. All legal persons are required to obtain a Commercial Registration (CR) from the MOIC, moreover, they are obligated to inform the MOIC regarding any changes in basic information. The CR certificate includes the following information and is publicly available through the central registry system Sijilat and consists of: • Commercial Registration number and establishment date. • Name of the legal representative of the establishment. • The legal form of the establishment. • Commercial name of the establishment. • Registration expiry date. • Activity/Business License (once the necessary approvals/licenses have been obtained). 41. The Sijilat portal is also utilized by the competent authorities, through direct access to essential business information, licensing details, and compliance records to ensure proper oversight and enforcement of regulations across various sectors. 42. Regarding beneficial ownership information, Bahrain follows a multi-pronged approach that ensures BO information can be accessed and determined in a timely manner by competent authorities through MOIC’s Sijilat UBO portal and by using a company approach where companies are required to obtain and hold adequate, accurate and up-to-date information on the company’s own beneficial ownership, and cooperate with competent authorities to the fullest extent possible to make information available in order to determine the beneficial owner. UBO information is also available through others sources; including FIs and DNFBPs, to provide accurate and up-to-date information on the company's beneficial ownership.