THE KINGDOM OF BAHRAIN’S NATIONAL RISK ASSESSMENT 2025
38 before it can be traded. This measure ensures transparency and traceability thereby reducing the risk of money laundering through smuggling or unverified gold. Overall Risks 175. While the sector is inherently exposed to ML risks. It’s significantly mitigated by a proactive regulatory measure that prohibits cash transactions exceeding 3,000 BHD (nearly $8000) as per the MO no 103 of 2021 (art. 3/10), which is a threshold set far below the FATF methodology, which states that dealers in precious metals and dealers in precious stones are subject to obligations when they engage in any cash transaction with a customer equal to or above USD/EUR 15,000 ( FATF Rec 22), thus forcing all high-value transactions into the regulated banking system. In Bahrain, Cash transactions are limited to a maximum of 3,000 BHD and transactions above 3000 BHD are accepted through banking channels only. These measures have been introduced to mitigate the risk of misusing the sector. 176. However, till now, merchants operating in the sector are required to conduct CDD, record keeping, and STR reporting measures when buying or selling gold or other precious metals for all transactions. 177. Overall, given the volume in transactions, industry nature, mitigatory measures, and supervisory controls the jewellery and precious metals sector in Bahrain is rated to medium-low ML risk. Real Estate Agents Introduction 178. The real estate sector in the Kingdom of Bahrain is a key component of the national economy, contributing to economic growth and investment opportunities. Recognizing the sector’s importance, the Real Estate Regulatory Authority (RERA) was established with the issuance of Royal Decree No. 27 of 2017 to create a robust and safe regulatory environment that fosters investor confidence while protecting the rights of all stakeholders. 179. Real estate transactions in Bahrain can be carried out directly between parties or through brokers or agents appointed by either party. All contracts for the sale or purchase of real estate are notarized by public notaries operating under the supervision of the MOJ as stated above on AML/CFT/CPF obligation. 180. RERA’s mandate is to ensure that the sector operates in a transparent and secure manner in alignment with international best practices. This includes ensuring proper licensing and oversight of persons operating in the real estate sector and ensuring adequate customer and investor protection. 181. Agents operating in Bahrain's real estate sector are licensed by RERA and must adhere to Decision No. (2) of 2021 on AML/CFT/CPF obligation in Real Estate Sector. These regulations enhance safeguards to ensure the real estate sector remains protected against criminal exploitation. 182. RERA implements comprehensive licensing requirements and has increased transparency within the market by requiring all brokers, valuers, property managers and real estate developers to hold a RERA license. Mandating licensing of developers and developments has strengthened the regulatory framework by identifying and prohibiting unlicensed real estate activities.
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