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Sanctions:
November 28, 2011 - The Arab League (comprising 22 Arab
member states), of which this country is a member, has approved
imposing sanctions on Syria. These include: -
* Cutting off transactions with the Syrian central bank
* Halting funding by Arab governments for projects in Syria
* A ban on senior Syrian officials travelling to other Arab countries
* A freeze on assets related to President Bashar al-Assad's
government
The declaration also calls on Arab central banks to monitor
transfers to Syria, with the exception of remittances from Syrians
abroad.
For further information, click here
The Arab League (comprising 22 Arab member states), of which
this country is a member, has boycotted Israel in a systematic
effort to isolate Israel economically in support of the Palestinians,
however, the implementation of the boycott has varied over time
among member states..
There are three tiers to the boycott. The primary boycott prohibits
the importation of Israeli-origin goods and services into boycotting
countries. The secondary boycott prohibits individuals, as well as
private and public sector firms and organizations, in member
countries from engaging in business with any entity that does
business in Israel. The Arab League maintains a blacklist of such
firms. The tertiary boycott prohibits any
entity in a member country from doing business with a company or
individual that has business dealings with U.S. or other firms on
the Arab League blacklist.
____________________________________________________
Offshore Jurisdiction Blacklists:
Information unavailable.
____________________________________________________
US State Department Money Laundering Report - 2011
Bahrain is a leading financial center in the Gulf region. In contrast
with its Gulf Cooperation Council (GCC) neighbors, Bahrain has a
primarily service-based economy, with the financial sector
providing more than 20 percent of GDP. It hosts a diverse group
of financial institutions, including 189 banks, 22 moneychangers
and money brokers, and several other investment institutions,
including 89 insurance companies. The greatest risk of money
laundering stems from illicit proceeds of foreign origin that transit
the country. The vast network of Bahrain’s banking system, along
with its geographical location in the Middle East as a transit point
along the Gulf and into Southwest Asia, may attract money
laundering activities. Bahrain does not have a significant black
market of smuggled goods or known linkages to drug trafficking.
Khalifa bin Salman Port, Bahrain's major port, provides a free
transit zone to facilitate the duty-free import of equipment and
machinery. Another free zone is located in the North Sitra
Industrial Estate. Raw materials intended for processing in
Bahrain, and machinery imported by Bahraini-owned firms, are
also exempt from duty; the imported goods may be stored duty-
free. These free-zones are not a significant source for money
laundering/terrorist financing. The informal and non-bank financial
sector are regulated and investigated similarly to the formal sector.
DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO
CRIMINALIZATION OF MONEY LAUNDERING:
“All serious crimes” approach or “list” approach to predicate
crimes: All serious crimes
Legal persons covered: criminally: YES civilly: YES
CRIMINALIZATION OF TERRORIST FINANCING:
Ability to freeze terrorist assets without delay: YES
UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES
(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)
KNOW-YOUR-CUSTOMER RULES:
Covered entities: Banks and all other financial institutions,
investment houses, insurance firms, money exchangers,
brokers/dealers, real estate brokers, gold dealers, financial
intermediaries, and attorneys
Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES
SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:
Covered entities: Banks and all other financial institutions,
investment houses, insurance firms, money exchangers,
brokers/dealers, real estate brokers, gold dealers, auto dealers,
jewelers, and attorneys
Number of STRs received and time frame: 319 from January to
September 2010
Number of CTRs received and time frame: Not applicable
MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:
Prosecutions: Not available
Convictions: 0 in 2010
Assets forfeited: criminally: Not available civilly: Not applicable
RECORDS EXCHANGE MECHANISM:
With U.S.: NO
With other governments/jurisdictions: YES
Bahrain hosts the Secretariat and is a member of the Middle East
and North Africa Financial Action Task Force (MENFATF), a FATF-
style regional body. Its most recent mutual evaluation can be
found here:
ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:
The Ministry of Social Development increased supervision over
non-profit organizations and charities in 2010. In September
2010, the Ministry forced all charities to transfer their legal status
to that of "society;" this classification allows the Ministry to
oversee all financial transactions. The Ministry circulated an order
to freeze twenty charities until they amended their status to that of
a society.
There is an over-reliance on suspicious transaction reporting to
initiate money laundering investigations. Awareness within the
capital markets and designated non-financial businesses and
professions regarding STR reporting obligations is inconsistent.
Cash transaction reporting is not separated from suspicious
transaction reporting requirements. Tipping off is not prohibited.
Bahrain uses a controversial definition of terrorism. One provision
of Law 54 is a revised definition of terrorism that is based on the
Organization of the Islamic Conference definition. Article 2
excludes from the definition of terrorism acts of struggle against
invasion or foreign aggression, colonization, or foreign supremacy
in the interest of freedom and the nation’s liberty.
Bahrain does not have a mutual legal assistance agreement with
the United States. Information is exchanged on a case-by-case
basis.
____________________________________________________
US State Dept Narcotics Report 2011 (introduction):
No report available
____________________________________________________
US State Dept Trafficking in Persons Report 2011
(introduction):
(Tier 2)
Bahrain is a destination country for men and women subjected to
forced labor and sex trafficking. Men and women from India,
Pakistan, Nepal, Sri Lanka, Bangladesh, Indonesia, Thailand, the
Philippines, Ethiopia, and Eritrea migrate voluntarily to Bahrain to
work as domestic workers or as unskilled laborers in the
construction and service industries. Some, however, face
conditions of forced labor after arriving in Bahrain, through use of
such practices as unlawful withholding of passports, restrictions
on movement, contract substitution, nonpayment of wages,
threats, and physical or sexual abuse. A study by the Bahrain
government’s Labor Market Regulatory Authority (LMRA) found
that 65 percent of migrant workers had not seen their employment
contract, and that 89 percent were unaware of their terms of
employment upon arrival in Bahrain. Many labor recruitment
agencies in Bahrain and source countries require workers to pay
high recruitment fees – a practice that makes workers highly
vulnerable to forced labor once in Bahrain. The LMRA study
found that 70 percent of foreign workers borrowed money or sold
property in their home countries in order to secure a job in
Bahrain. Some Bahraini employers illegally charge workers
exorbitant fees to remain in Bahrain working for third-party
employers (under the “free visa” arrangement). The LMRA
estimates that approximately 10 percent of migrant workers were
in Bahrain under illegal “free visa” arrangements – a practice that
can contribute to debt bondage – while the Bahrain Chamber of
Commerce and Industry puts the figure at 25 percent. Women
from Thailand, the Philippines, Morocco, Jordan, Syria, Lebanon,
Russia, China, Vietnam, and Eastern European states are
subjected to forced prostitution in Bahrain.
The Government of Bahrain does not fully comply with the
minimum standards for the elimination of trafficking; however, it is
making significant efforts to do so. The government continued to
investigate and prosecute forced prostitution cases and convicted
nine trafficking offenders during the reporting period. In addition,
the government assisted 17 victims of forced prostitution.
Nonetheless, there were no reports of government efforts to
punish forced labor crimes nor any indication that the
Government of Bahrain took steps to institute a formal victim
identification procedure or otherwise improve victim protection
efforts during the reporting period. The government’s lack of
efforts to acknowledge and address forced labor remains a key
gap in its anti-trafficking response.
For full report click here
____________________________________________________
US State Dept Terrorism Report 2010
Overview: The Bahraini government worked to actively counter
terrorist finance, enhanced border control capability, contributed
manpower to international counterterrorism operations, realign
internal responsibilities, and successfully prosecuted a number of
cases under its 2006 counterterrorism law.
Legislation and Law Enforcement: Key to several Bahraini
counterterrorism successes this year was a decision by the King
to realign internal intelligence, analytical, and counterterrorism
responsibilities in various government ministries under the
Bahrain National Security Agency, which has resulted in a clearer
delineation of roles and responsibilities allowed for greater
capacity building and increased interagency cooperation.
Bahraini law enforcement actions included:
* On January 26, the High Criminal Court convicted and
sentenced to five-year prison terms two Bahraini citizens affiliated
with al-Qa'ida of plotting a terrorist attack against U.S. diplomatic
and naval interests. On May 30, the court's decision was upheld
by the Supreme Criminal Appeals Court. Key to the successful
prosecution was the digital forensic evidence seized by Bahraini
law enforcement.
* On July 5, seven Bahraini citizens were convicted under the
2006 counterterrorism law and sentenced to life imprisonment for
their involvement in the March 2009 death of a Pakistani national
who was presumed to be a plain clothed police officer at the time
of the attack.
* On July 6, two Bahraini citizens were convicted by the High
Criminal Court of plotting an April 2009 terrorist attack with a
homemade bomb and were each sentenced to a 10-year prison
term.
* During August to November, Bahraini law enforcement arrested
at least 200 men, including minors, and held many of them under
the counterterrorism law for various offenses. Twenty-five
Bahraini citizens (including two in absentia) have been charged
and the trial was ongoing at year's end. The arrests and
subsequent prosecutions have been criticized by local and
international human rights organizations as being political in
nature, and there have been claims of mistreatment and coerced
confessions by some of the detainees' defense counsels.
Countering Terrorist Finance: Bahrain worked actively to counter
terrorist finance and hosted the Secretariat for the Middle East
and North Africa Financial Action Task Force (MENAFATF), a
Financial Action Task Force-style regional body. Bahrain worked
cooperatively with its banks on anti-money laundering and
counterterrorist finance (AML/CTF) issues. Bahraini law
enforcement and customs officials also continued to build
AML/CTF capacity through extensive training. In October, Bahrain
imprisoned a Syrian national who had been convicted in absentia
of terrorist financing by Bahraini courts and sentenced to a five-
year prison term in February 2009. Despite progress, Bahrain has
yet to adequately amend the law banning money laundering and
combating terrorism finance. In addition, Bahrain’s designated
non-financial businesses and professions remained vulnerable to
terrorist financing, due primarily to the non-issuance of legislation
for regulating and monitoring the sector. Bahrain was asked to
provide MENAFATF a follow up report in 2011 outlining progress.
Regional and International Cooperation: Since formally endorsing
the Global Initiative to Combat Nuclear Terrorism in March 2008,
Bahrain has worked to expand air, sea, and causeway border
control points through increased training, internal cooperation,
and staffing the border with officers capable of recognizing and
interdicting nuclear proliferation materials such as centrifuges and
commercially banned items. Bahrain acceded to the International
Convention for the Suppression of Acts of Nuclear Terrorism as
well as the Convention on the Physical Protection of Nuclear
Material and its 2005 Amendment.
Countering Radicalization and Violent Extremism: Bahrain's efforts
to counter radicalization and violent extremism have been
spearheaded by the Ministry of Justice and Islamic Affairs (MJIA).
The MJIA organized regular workshops and seminars for imams
from both the Sunni and Shia sects, and expanded its
international scholarship program to include religious schools in
Egypt, Jordan, and the United Arab Emirates. It also completed an
annual review of schools' Islamic Studies curriculum to evaluate
interpretations of religious texts.
____________________________________________________
Links:
Worldwide AML Legislation (International Bar Association)
Anti-Money Laundering Unit (AMLU)
November 28, 2011 - The Arab League (comprising 22 Arab
member states), of which this country is a member, has approved
imposing sanctions on Syria. These include: -
* Cutting off transactions with the Syrian central bank
* Halting funding by Arab governments for projects in Syria
* A ban on senior Syrian officials travelling to other Arab countries
* A freeze on assets related to President Bashar al-Assad's
government
The declaration also calls on Arab central banks to monitor
transfers to Syria, with the exception of remittances from Syrians
abroad.
For further information, click here
The Arab League (comprising 22 Arab member states), of which
this country is a member, has boycotted Israel in a systematic
effort to isolate Israel economically in support of the Palestinians,
however, the implementation of the boycott has varied over time
among member states..
There are three tiers to the boycott. The primary boycott prohibits
the importation of Israeli-origin goods and services into boycotting
countries. The secondary boycott prohibits individuals, as well as
private and public sector firms and organizations, in member
countries from engaging in business with any entity that does
business in Israel. The Arab League maintains a blacklist of such
firms. The tertiary boycott prohibits any
entity in a member country from doing business with a company or
individual that has business dealings with U.S. or other firms on
the Arab League blacklist.
____________________________________________________
Offshore Jurisdiction Blacklists:
Information unavailable.
____________________________________________________
US State Department Money Laundering Report - 2011
Bahrain is a leading financial center in the Gulf region. In contrast
with its Gulf Cooperation Council (GCC) neighbors, Bahrain has a
primarily service-based economy, with the financial sector
providing more than 20 percent of GDP. It hosts a diverse group
of financial institutions, including 189 banks, 22 moneychangers
and money brokers, and several other investment institutions,
including 89 insurance companies. The greatest risk of money
laundering stems from illicit proceeds of foreign origin that transit
the country. The vast network of Bahrain’s banking system, along
with its geographical location in the Middle East as a transit point
along the Gulf and into Southwest Asia, may attract money
laundering activities. Bahrain does not have a significant black
market of smuggled goods or known linkages to drug trafficking.
Khalifa bin Salman Port, Bahrain's major port, provides a free
transit zone to facilitate the duty-free import of equipment and
machinery. Another free zone is located in the North Sitra
Industrial Estate. Raw materials intended for processing in
Bahrain, and machinery imported by Bahraini-owned firms, are
also exempt from duty; the imported goods may be stored duty-
free. These free-zones are not a significant source for money
laundering/terrorist financing. The informal and non-bank financial
sector are regulated and investigated similarly to the formal sector.
DO FINANCIAL INSTITUTIONS ENGAGE IN CURRENCY
TRANSACTIONS RELATED TO INTERNATIONAL NARCOTICS
TRAFFICKING THAT INCLUDE SIGNIFICANT AMOUNTS OF US
CURRENCY; CURRENCY DERIVED FROM ILLEGAL SALES IN
THE U.S.; OR THAT OTHERWISE SIGNIFICANTLY AFFECT THE
U.S.: NO
CRIMINALIZATION OF MONEY LAUNDERING:
“All serious crimes” approach or “list” approach to predicate
crimes: All serious crimes
Legal persons covered: criminally: YES civilly: YES
CRIMINALIZATION OF TERRORIST FINANCING:
Ability to freeze terrorist assets without delay: YES
UN lists of designated terrorists or terrorist entities distributed to
financial institutions: YES
(Please refer to the Department of State’s Country Reports on
Terrorism, which can be found here: http://www.state.
gov/s/ct/rls/crt/)
KNOW-YOUR-CUSTOMER RULES:
Covered entities: Banks and all other financial institutions,
investment houses, insurance firms, money exchangers,
brokers/dealers, real estate brokers, gold dealers, financial
intermediaries, and attorneys
Enhanced due diligence procedures for PEPs: Foreign: YES
Domestic: YES
SUSPICIOUS TRANSACTION REPORTING REQUIREMENTS:
Covered entities: Banks and all other financial institutions,
investment houses, insurance firms, money exchangers,
brokers/dealers, real estate brokers, gold dealers, auto dealers,
jewelers, and attorneys
Number of STRs received and time frame: 319 from January to
September 2010
Number of CTRs received and time frame: Not applicable
MONEY LAUNDERING CRIMINAL
PROSECUTIONS/CONVICTIONS:
Prosecutions: Not available
Convictions: 0 in 2010
Assets forfeited: criminally: Not available civilly: Not applicable
RECORDS EXCHANGE MECHANISM:
With U.S.: NO
With other governments/jurisdictions: YES
Bahrain hosts the Secretariat and is a member of the Middle East
and North Africa Financial Action Task Force (MENFATF), a FATF-
style regional body. Its most recent mutual evaluation can be
found here:
ENFORCEMENT AND IMPLEMENTATION ISSUES AND
COMMENTS:
The Ministry of Social Development increased supervision over
non-profit organizations and charities in 2010. In September
2010, the Ministry forced all charities to transfer their legal status
to that of "society;" this classification allows the Ministry to
oversee all financial transactions. The Ministry circulated an order
to freeze twenty charities until they amended their status to that of
a society.
There is an over-reliance on suspicious transaction reporting to
initiate money laundering investigations. Awareness within the
capital markets and designated non-financial businesses and
professions regarding STR reporting obligations is inconsistent.
Cash transaction reporting is not separated from suspicious
transaction reporting requirements. Tipping off is not prohibited.
Bahrain uses a controversial definition of terrorism. One provision
of Law 54 is a revised definition of terrorism that is based on the
Organization of the Islamic Conference definition. Article 2
excludes from the definition of terrorism acts of struggle against
invasion or foreign aggression, colonization, or foreign supremacy
in the interest of freedom and the nation’s liberty.
Bahrain does not have a mutual legal assistance agreement with
the United States. Information is exchanged on a case-by-case
basis.
____________________________________________________
US State Dept Narcotics Report 2011 (introduction):
No report available
____________________________________________________
US State Dept Trafficking in Persons Report 2011
(introduction):
(Tier 2)
Bahrain is a destination country for men and women subjected to
forced labor and sex trafficking. Men and women from India,
Pakistan, Nepal, Sri Lanka, Bangladesh, Indonesia, Thailand, the
Philippines, Ethiopia, and Eritrea migrate voluntarily to Bahrain to
work as domestic workers or as unskilled laborers in the
construction and service industries. Some, however, face
conditions of forced labor after arriving in Bahrain, through use of
such practices as unlawful withholding of passports, restrictions
on movement, contract substitution, nonpayment of wages,
threats, and physical or sexual abuse. A study by the Bahrain
government’s Labor Market Regulatory Authority (LMRA) found
that 65 percent of migrant workers had not seen their employment
contract, and that 89 percent were unaware of their terms of
employment upon arrival in Bahrain. Many labor recruitment
agencies in Bahrain and source countries require workers to pay
high recruitment fees – a practice that makes workers highly
vulnerable to forced labor once in Bahrain. The LMRA study
found that 70 percent of foreign workers borrowed money or sold
property in their home countries in order to secure a job in
Bahrain. Some Bahraini employers illegally charge workers
exorbitant fees to remain in Bahrain working for third-party
employers (under the “free visa” arrangement). The LMRA
estimates that approximately 10 percent of migrant workers were
in Bahrain under illegal “free visa” arrangements – a practice that
can contribute to debt bondage – while the Bahrain Chamber of
Commerce and Industry puts the figure at 25 percent. Women
from Thailand, the Philippines, Morocco, Jordan, Syria, Lebanon,
Russia, China, Vietnam, and Eastern European states are
subjected to forced prostitution in Bahrain.
The Government of Bahrain does not fully comply with the
minimum standards for the elimination of trafficking; however, it is
making significant efforts to do so. The government continued to
investigate and prosecute forced prostitution cases and convicted
nine trafficking offenders during the reporting period. In addition,
the government assisted 17 victims of forced prostitution.
Nonetheless, there were no reports of government efforts to
punish forced labor crimes nor any indication that the
Government of Bahrain took steps to institute a formal victim
identification procedure or otherwise improve victim protection
efforts during the reporting period. The government’s lack of
efforts to acknowledge and address forced labor remains a key
gap in its anti-trafficking response.
For full report click here
____________________________________________________
US State Dept Terrorism Report 2010
Overview: The Bahraini government worked to actively counter
terrorist finance, enhanced border control capability, contributed
manpower to international counterterrorism operations, realign
internal responsibilities, and successfully prosecuted a number of
cases under its 2006 counterterrorism law.
Legislation and Law Enforcement: Key to several Bahraini
counterterrorism successes this year was a decision by the King
to realign internal intelligence, analytical, and counterterrorism
responsibilities in various government ministries under the
Bahrain National Security Agency, which has resulted in a clearer
delineation of roles and responsibilities allowed for greater
capacity building and increased interagency cooperation.
Bahraini law enforcement actions included:
* On January 26, the High Criminal Court convicted and
sentenced to five-year prison terms two Bahraini citizens affiliated
with al-Qa'ida of plotting a terrorist attack against U.S. diplomatic
and naval interests. On May 30, the court's decision was upheld
by the Supreme Criminal Appeals Court. Key to the successful
prosecution was the digital forensic evidence seized by Bahraini
law enforcement.
* On July 5, seven Bahraini citizens were convicted under the
2006 counterterrorism law and sentenced to life imprisonment for
their involvement in the March 2009 death of a Pakistani national
who was presumed to be a plain clothed police officer at the time
of the attack.
* On July 6, two Bahraini citizens were convicted by the High
Criminal Court of plotting an April 2009 terrorist attack with a
homemade bomb and were each sentenced to a 10-year prison
term.
* During August to November, Bahraini law enforcement arrested
at least 200 men, including minors, and held many of them under
the counterterrorism law for various offenses. Twenty-five
Bahraini citizens (including two in absentia) have been charged
and the trial was ongoing at year's end. The arrests and
subsequent prosecutions have been criticized by local and
international human rights organizations as being political in
nature, and there have been claims of mistreatment and coerced
confessions by some of the detainees' defense counsels.
Countering Terrorist Finance: Bahrain worked actively to counter
terrorist finance and hosted the Secretariat for the Middle East
and North Africa Financial Action Task Force (MENAFATF), a
Financial Action Task Force-style regional body. Bahrain worked
cooperatively with its banks on anti-money laundering and
counterterrorist finance (AML/CTF) issues. Bahraini law
enforcement and customs officials also continued to build
AML/CTF capacity through extensive training. In October, Bahrain
imprisoned a Syrian national who had been convicted in absentia
of terrorist financing by Bahraini courts and sentenced to a five-
year prison term in February 2009. Despite progress, Bahrain has
yet to adequately amend the law banning money laundering and
combating terrorism finance. In addition, Bahrain’s designated
non-financial businesses and professions remained vulnerable to
terrorist financing, due primarily to the non-issuance of legislation
for regulating and monitoring the sector. Bahrain was asked to
provide MENAFATF a follow up report in 2011 outlining progress.
Regional and International Cooperation: Since formally endorsing
the Global Initiative to Combat Nuclear Terrorism in March 2008,
Bahrain has worked to expand air, sea, and causeway border
control points through increased training, internal cooperation,
and staffing the border with officers capable of recognizing and
interdicting nuclear proliferation materials such as centrifuges and
commercially banned items. Bahrain acceded to the International
Convention for the Suppression of Acts of Nuclear Terrorism as
well as the Convention on the Physical Protection of Nuclear
Material and its 2005 Amendment.
Countering Radicalization and Violent Extremism: Bahrain's efforts
to counter radicalization and violent extremism have been
spearheaded by the Ministry of Justice and Islamic Affairs (MJIA).
The MJIA organized regular workshops and seminars for imams
from both the Sunni and Shia sects, and expanded its
international scholarship program to include religious schools in
Egypt, Jordan, and the United Arab Emirates. It also completed an
annual review of schools' Islamic Studies curriculum to evaluate
interpretations of religious texts.
____________________________________________________
Links:
Worldwide AML Legislation (International Bar Association)
Anti-Money Laundering Unit (AMLU)
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| Further Tables |
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*Please note that FATF deems that a country has significant aml deficiencies if any
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.
For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -
R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV
Please also note that any risk assessment should take into consideration all
follow-up reports.
of the 'Core' Recommendations, R1, R5, R10, R13, SRII, or SRIV are rated either
Partially of Non-Compliant. These are marked in red.
For FATF to remove a country from the regular follow-up process, it has to be rated
Compliant or Largely Compliant in the above mentioned Core Recommendations
and the following Key Recommendations: -
R3, R4, R23, R26, R35, R36, R40, SRI, SRIII, SRV
Please also note that any risk assessment should take into consideration all
follow-up reports.
| BAHRAIN |
| KnowYourCountry |
|
|
| Last Updated: 16 April 2012 |