THE KINGDOM OF BAHRAIN’S NATIONAL RISK ASSESSMENT 2025

17 43. MOIC has issued a Ministerial resolution (83) of 2020 regarding criteria, conditions and rules governing the disclosure of Ultimate Beneficial Owner (UBO) and is applicable to all registered structures. The Ministerial decision, as well as all other relevant laws and regulations has provided a clear definition of the ultimate beneficiary in line with the FATF definition of BO. The MOIC has solid controls to prevent criminal ownership and control of its supervised entities. Overall, all types of legal persons are required to inform MOIC about the ultimate beneficial owner information at the time of licensing/registering as stipulated in the ministerial resolution (83) of 2020. Subsequently, whenever changes in BO information occurs, companies have an obligation to disclose these changes. 44. Sanctions are enforced for submitting false BO information and failure to report or update BO information can result in administrative fines reaching up to 50,000 BHD, in accordance with Article 7 from the Ministerial Resolution (83) of 2020. Nominee shares and nominee directors, including the issuance of bearer shares, are restricted in Bahrain. Foreign Legal Structures 45. Number of legal persons registered and/or created owned or controlled by non-residents in Bahrain is expanding. This signifies the increase in the attractiveness for foreigners to form companies in the Kingdom. Nonetheless, the Kingdom of Bahrain does not allow a foreign bearer share entity to operate or own assets. 46. The MOIC has the authority to request financial reports from foreign companies in order to trace any changes in ownership and to ensure BO information is available. All documents, including identity of foreign investors, must be apostilled prior to submitting registration application. 47. Bahrain is active in international co-operation, and exchanges useful UBO information with foreign counterparts, which also mitigates the cross-border risks of misusing foreign legal structures. Legal Persons 48. In line with FATF’s recommendation 24, basic information on companies is available, recorded, and made available to the public. Sijilat, is Bahrain’s official commercial registration portal, designed to streamline business registration and regulatory processes. The platform provides a centralized database that enhances transparency, facilitates compliance with legal requirements, and enables real-time monitoring of commercial activities. Threat Assessment 49. The WB tool has assisted in rating the level of abuse of legal persons for money laundering based on law enforcement data and level of abuse based on threat perceptions and open sources. The law enforcement data analysed concern Suspicious Activity Reports/Suspicious Transaction Reports, criminal convictions, and other data. All variables for the indicator based on enforcement data rely on quantitative data concerning the level of detected cases where legal structures were used for ML purposes to support the ratings. The level of ML abuse based on threat perception and open sources was calculated based on credible open sources and public/private sector experts.