THE KINGDOM OF BAHRAIN’S NATIONAL RISK ASSESSMENT 2025

18 50. There was a number of Mutual Legal Assistance requests were sent/received by competent authorities related to ML involving legal persons within the Kingdom. However, given the robust ultimate beneficial owner requirements, demonstrated in the legal framework and in the Sijilat system, relevant authorities are able to identify the ultimate natural persons exploiting such legal structures. 51. Supervisory authorities, FIs, and DNFBPs submit their STRs to the Financial Intelligence National Center (FINC) whenever they find out suspicious activities relating to legal entities. These include individuals exploiting the operations of the legal persons in ML. The findings of the threat assessment revealed that the level of threat is categorized as medium . National Vulnerability 52. A review and analysis were conducted of the vulnerabilities and available mitigatory controls on legal structures. The national vulnerability assessment consists of two elements: (1) an assessment of the attractiveness of the country as an international center for formation or registration of legal structures for non-residents – that is, “Attractiveness for Non-Resident Incorporation” (ANRI); and (2) an assessment of the strength of the Kingdom’s mitigation measures to address risks of illicit abuse of legal structures. 53. The ANRI score is a measure of a country’s general attractiveness as a formation or incorporation center for non-residents, considering different types of legal structures – companies, partnerships, foundations, and others. The score includes features related to the legal, institutional, economic, regulatory, and political frameworks that impact its attractiveness for the provision of company formation services (and related professional services) to non-resident individuals and non-resident legal entities. The ANRI score was reached by a partaking of competent authorities such as the National Bureau for Revenue (NBR) and the (CBB). 54. The ratings of the given input variables for the ANRI score were reached to a medium level of attractiveness which implies features for bona fide business investments and may also suggest an increase its attractiveness to illicit actors seeking to form legal structures to hide or invest proceeds of crime. Nonetheless, a high level of attractiveness as a location for forming legal structures does not directly translate into a higher level of risk of abuse, but it can mean that stronger mitigation measures are needed when compared to a jurisdiction with a lower attractiveness level (that is, with a low ANRI score). 55. Subsequently, the strength of the country's existing mitigation measures against abuse of legal persons has been determined by intermediate variables and indicators such as, quality of corporate registry, accessibility of BO information, verification mechanism, enforcement of sanctions against violations of BO reporting rules, and controls against opaque structures. When assessing the quality of the national registry (Sijilat) in Bahrain, there is close to comprehensive coverage of all legal entities registered, and the level of accurate and up-to-date basic company information available in the national registry is high, online access to basic company information exists free of charge. LEAs have direct access to beneficial ownership information.