THE KINGDOM OF BAHRAIN’S NATIONAL RISK ASSESSMENT 2025

19 56. Overall, all legal persons in Bahrain are subject to transparency requirements that includes the appointment of a natural person as the ultimate beneficial owner and there is an obligation to update the ultimate beneficial owner (UBO). In addition, discrepancies are being traced, and appropriate actions being taken. 57. The score for strength of mitigation measures was combined with the ANRI score to reach the national vulnerability level generated by the WB tool is of medium level. Accordingly, the ML vulnerabilities associated with legal persons are determined to be medium . Overall Risks 58. The tool calculated a threat score, indicating a medium level of threat, which is supported by some identified misuse of legal entities in the STRs submitted particularly from MOIC. The national vulnerability score is also categorised as medium. This is a combination of a high Attractiveness for Non-Resident Incorporation (ANRI) score and the strength of the country's mitigation measures. While Bahrain has strong mitigation measures in place, such as comprehensive beneficial ownership requirements, a high-quality corporate registry, and robust enforcement actions, the overall risk is determined to be medium . Legal Arrangements Trusts 59. All trusts within the Kingdom of Bahrain are provided services by Trust Service Providers (TSPs) licensed by the CBB. Trusts are required to register through a TSP within the CBB’s trust registry office. A trust is only valid if it is created by virtue of a notarized trust Instrument signed by both the Settlor and Trustee, or by the Settlor alone where the trust is created by a Unilateral Declaration of Trust. Trust instruments are notarized at a branch office within CBB’s headquarters. All details of settlers and beneficiaries are included within the trust instrument and any changes to this information must also be submitted to the CBB. TSPs offer a wide variety of services to trusts, including the creation and management of trust structures for asset protection, estate management, management of shares and accounting services. Threat Assessment 60. It is recognised that the use of trusts in ownership and control structures that provide for the separation of legal ownership from beneficial ownership, and often having low transparency of ownership and control, is considered a typology used to obscure the ultimate beneficial owner, hence is deemed to be a threat to ML. 61. Nonetheless, law enforcement data revealed that a trivial number of STRs were identified related to trusts during the assessment period, indicating a low level of engagement in suspicious behaviour. In addition, no reported cases of domestic abuse were identified in the sample period. Therefore, the ML threats associated with the sector are determined to be low .