THE KINGDOM OF BAHRAIN’S NATIONAL RISK ASSESSMENT 2025

40 Notaries Sector Introduction 189. The notary sector in Bahrain plays a critical role in the legal and financial systems, providing services to authenticate documents and transactions. The MOJ oversees the regulatory framework to ensure compliance with legal standards, including AML/CFT/CPF. Notaries are required to comply with Decision No. (28) of 2021 on AML/CFT/CPF obligation Overall Risks 190. The MOJ conducts regular audits and inspections to ensure compliance with AML/CFT/CPF regulations. This includes field inspections to assess records, client verification, and adherence to legal standards. Additionally, circulars were issued regarding sanctions to ensure notaries compliance with international regulations. 191. As a legal profession and based on the FATF methodology, notaries are obliged to report suspicious transactions and conduct CDD requirements in the five conditions stipulated in Recommendation 22 of the FATF methodology (stated above in lawyer’s section), which might limit the scope and affect the risks associated with this sector. 192. Considering that their business is mainly legalization of operations, low level of risk exposure, and the factors mentioned, the notaries sector is rated as low . Trusts Service Providers Introduction 193. Trust Service Providers (TSPs) offer services related to the establishment, administration and management of trusts. More specifically, trust services are defined as: • Establishment of trusts; • Administration of trusts in accordance with the provisions of the trust deed; • Providing related ancillary services to trusts in accordance with the provisions of the trust deed; and • Providing financial advisory services to trust business clients only. 194. All trusts are required to register with the CBB by a trustee (TSP licensed by the CBB and domiciled in Bahrain). Overall Risks 195. The TSP sector in Bahrain is subject to various AML/CFT/CPF controls to mitigate the risks associated with money laundering and terrorist financing. These controls include beneficial ownership transparency as the owners of the assets and their beneficiaries are known to the TSPs and the CBB. The details of settlors, trustees, protectors, and beneficiaries are provided in the trust instrument, which is submitted to the CBB as part of the registration process. Any amendments to the trust instrument must also be submitted to the CBB.