THE KINGDOM OF BAHRAIN’S NATIONAL RISK ASSESSMENT 2025

39 183. The real estate sector is globally considered as a potential venue for money laundering risks due to its high-value transactions and involvement of multiple intermediaries. RERA collaborates with the Financial Intelligence National Center and other stakeholders to ensure compliance with Bahrain’s AML/CFT/CPF laws and regulations. Overall Risks 184. RERA has introduced specific measures aiming at enhancing compliance and minimizing exposure to financial crime in Bahrain’s real estate sector. More specifically, Resolution 2 of 2021 establishes a robust regulatory framework with clear procedures for licensed entities to mitigate financial crime risks. 185. The provisions outlined in Resolution 2 of 2021 require licensees to implement customer due diligence requirements, retain records of business relationships and establish mechanisms for reporting suspicious transactions. To further mitigate inherent risk, RERA has implemented a strict regulatory cap, mandating that all real estate cash transactions over 2,000 BHD must be processed through banking channels. 186. Given the threats, vulnerabilities, controls and regulatory oversight of the real estate sector, the overall risks associated with the sector are assessed as medium-low. Accountancy and the Audit Sector Introduction 187. The auditing and accountancy sector in Bahrain is highly regulated and requires significant professional qualifications and experience for market entry. This rigorous entry process, including certifications like CPA or ACCA, ensures a high level of control and expertise within the sector. Additionally, the sector is overseen by a disciplinary council that monitors compliance and takes action against any misconduct. Overall Risks 188. This strict oversight over this sector is essential due to the widespread influence of auditors and accountants in various businesses and legal entities. As a profession, firms operating under this subsector are required to report any suspicious transactions and conduct CDD requirements as stipulated in the conditions of Recommendation 22 in the FATF methodology (the same as lawyers, stated above). It’s worth noting that auditors have restrictions on business as per Trade Law no (7) of 1987 and its amendments, and therefore, most of the activities mentioned in the FATF Methodology are out of their scope. However, the sector is under MOIC rigid supervision monitoring their AML compliance activities based on their operations which might limit the scope affecting the risks associated by the sector. Given the business nature, scope, limited number of licensees, and the mitigatory measures, it is concluded that the threat level of ML in auditing and accountancy firms is low risk.