THE KINGDOM OF BAHRAIN’S NATIONAL RISK ASSESSMENT 2025

21 National Vulnerability 68. To register waqfs, individuals are required to be registered through court and where the MOJ oversees the assets under management. All parties in the establishment and registration phase shall be known and ultimate beneficiaries are disclosed. More importantly, MOJ ensures that the proceeds from waqfs are used effectively as mentioned in initial purpose, which includes public benefit including education, healthcare, religious institutions, and social services. 69. There is an agreement that mandates the administrator ( Nather ) to open a specific bank account for the waqf and submit biannual reports detailing all income and expenses, as well as an annual audited financial statement, to the waqf council. These measures are in place to secure the waqf’s compliance with AML/CFT regulations and also to protect waqf’s money as well. 70. The ML risks associated with the waqfs in Bahrain are mitigated by rigorous measures taken to ensure transparency of beneficial ownership information. The size of the sector is small and there is no exposure to cross-border transactions. Therefore, given that Waqfs in the Bahrain are well controlled and mainly used for charitable purposes and no cases were detected hence the low threat level and the vulnerability score categorized for the Waqf sector is low . Overall Risks 71. Based on the assessment provided, the overall risk of waqfs being misused for ML/TF in Bahrain is low . The threat assessment is rated as low due to the complete absence of reported cases of waqf abuse for ML/TF, as confirmed by law enforcement agencies. This is further reinforced by the stringent supervision from the Ministry of Justice and Islamic Affairs, which governs all waqfs under Shari’a law and mandates in-depth due diligence. Similarly, the national vulnerability is also deemed low, due to several mitigating factors. These include mandatory court registration for waqfs, the requirement for full disclosure of ultimate beneficiaries, and the small size of the sector. The administrator's obligation to maintain a dedicated bank account and provide financial reports to the waqf council further strengthens these controls. Importantly, Waqf ownership cannot be changed. The combination of a low threat and low vulnerability results in a final overall risk score of low . MONEY LAUNDERING THREAT ASSESSMENT AT A NATIONAL LEVEL Threat Overview and Context 72. The Kingdom of Bahrain’s regulatory authorities have kept pace with its fast-growing financial sector and other sectors with regards to digital transformation. The regulatory authorities have implemented measures to mitigate the risks of new and emerging technologies and to ensure a stable and secure financial environment. 73. Bahrain's AML/CFT framework is primarily governed by Law No. (4) of 2001. Recent amendments, including Law No. (25) of 2013, have strengthened this framework. To support this legal framework,