The Central Bank of Bahrain (CBB), as Bahrain’s capital market regulator, requires capital market service providers (CMSPs) to identify and assess money-laundering and financing of terrorism (ML/FT) risks within their businesses and implement anti-money laundering and combatting financing of terrorism (AML/CFT) frameworks. In Bahrain, CMSPs include all companies listed on the Bahrain Bourse.

Understanding AML/CFT risks

All CMSPs are required to comply with CBB and Bahrain Bourse regulations, which include:

  • Identifying and assessing ML/FT risks within the business
  • Appointing a money laundering reporting officer (MLRO) and deputy MLRO
  • Developing and documenting an AML/CFT manual
  • Developing frameworks to monitor and test compliance
  • Reporting suspicious transactions
Contents of an AML/CFT manual

Having identified and assessed ML/FT risks, CMSPs are required to design and implement AML/CFT frameworks proportional to the size and scale of their business, with an AML/CFT policy manual a critical framework component. Manuals typically include:

  • An introduction to AML/CFT
  • Scope of application
  • Regulatory requirements – including Bahrain’s AML law, CBB regulations and Bahrain Bourse requirements
  • Governance frameworks (including responsibilities of board and senior management)
  • MLRO’s appointment, responsibilities and independence requirements
  • Customer risk profiling and acceptance criteria
  • Sanctions frameworks and screening processes
  • Reporting requirements (internal and external)
  • Inspections and investigations
  • Training requirements
  • Record keeping and information updates
  • Regular review requirements
  • Fines, penalties and internal disciplinary measures
How can Keypoint help?

Using their extensive financial crime, compliance, AML and risk management experience, our financial regulatory compliance (FRC) professionals develop practical, sector-specific approaches that help clients to comply with regulatory obligations while creating value by providing efficient and cost-effective solutions.


Ahmed Ayyad
Executive Manager
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