THE KINGDOM OF BAHRAIN’S NATIONAL RISK ASSESSMENT 2025

20 National Vulnerability 62. Regarding mitigation measures, the CBB has high quality of regulation and supervision of TSPs given its clear procedures and strong controls to enhance the quality of AML regulation of TSPs. Risks related to ownership structures are mitigated given that beneficial ownership and beneficiary disclosure requirements are in place and are available to TSPs and are supervised by the CBB. The risks in terms of size are minimal given that the total number of trusts within Bahrain is relatively small. 63. The world bank tool’s analysis reveal that cross border risk exposure is limited and is considered low given that the primary location of the trusts’ business operations and ownership structures are domestic. In addition, based on available data, the risk of exposure to jurisdictions of origin for proceeds of crime is low. As such, the vulnerabilities associated with trusts are categorized as low . Overall Risks 64. A low threat assessment is determined by the minimal number of (STRs) and the absence of identified domestic abuse cases during the assessment period. The limited scale of misuse is attributed to effective supervisory controls and the small size of the trust sector within the jurisdiction. National vulnerability is also categorized as low, a conclusion supported by the presence of robust mitigation measures. These include the high-quality regulation and supervision of Trust Service Providers (TSPs) by the CBB, which enforces stringent procedures and controls. Furthermore, risks are contained through mandatory beneficial ownership and beneficiary disclosure requirements, the small number of active trusts, and a low cross-border risk exposure, as the majority of trusts have domestic operations and ownership structures. Accordingly, the overall money laundering (ML) risk associated with trusts is assessed as low . Waqfs 65. Waqfs are legal arrangements where property or money can be kept in favour of (endowed to) the public or a particular individual, for a permanent period (normally a lifetime) and no ownership changes. Generally, waqfs can be perceived as religious funds donated for public use, usually used in jurisdictions that apply Islamic law. There are three types of waqf in Bahrain, depending on how the waqf is created. The waqf councils execute the terms of the waqf, together with the administrator of the waqf ( Nather ). 66. All waqfs in the Kingdom of Bahrain are governed by Shari’a and are supervised by the Ministry of Justice and Islamic Affairs and Waqf (MOJ) through Ministerial Decision No. 3 of 2017 which includes the procedures for waqf creation. MOJ ensures that waqf properties and assets are identified, managed and are in line with the intended purposes. Threat Assessment 67. Waqfs are primarily used for charitable purposes in Bahrain. MOJ maintains robust rules and regulations for the establishment and management of waqfs going through in-depth due diligence. During the assessment period, no cases were reported regarding suspicions of the abuse of Waqfs in ML/TF. Therefore, the ML/TF threats associated with the sector are determined to be low .