AML & CTF

Money laundering and financing terrorism has been identified as a major threat to the International financial services community. The Bahrain Government, in common with Bahrain Monetary Authority and Capital Market Authority (CMA) in Bahrain, has passed legislation designed to prevent money laundering which imposes certain requirements upon institutions licensed in their jurisdiction.

As Bahrain Al Muharraq Group Limited is registered, authorized and based in Bahrain, Bahrain legislation is of primary importance to the company. Al Muharraq Group Limited has adopted the Bahrain requirements as a statement of the minimum standards to be adopted to minimize the use of its products and services for money laundering and terrorist financing.

Legal and Regulatory Framework

The principle Bahrain legislations issued in this regards are as follows:

• The Executive Regulations for the Law on Combating Terrorism Crimes and Its Financing issued pursuant to Bahrain Cabinet Resolution No. 228, dated 05/02/1440H, corresponding to 01/08/2019G.
• The guide to executing the implementation mechanism of the Security Council resolutions related to preventing the proliferation of weapons of mass destruction and its financing issued by Royal Decree on 01/03/1439H corresponding to 11/19/2017G and CMA circular.
• CMA circular number 6/6/2184/19 dated 18/07/1440 H corresponding to 25/03/2019 G related to indicators of concealing the identity of true beneficiary.

Policy Objectives

The objectives of this Policy are:

• To prevent use of Al Muharraq Group Limited’s products or services for money laundering.
• To prevent damage to Al Muharraq Group Limited’s name and reputation by association with money launderers.
• To ensure that Al Muharraq Group Limited complies with money laundering legislation / regulations wherever it does business.

Policy Scope

Meeting the requirements of this Policy is considered of paramount importance and takes precedence over other commercial aspects of managing our customer relationships.

Policy Application

Al Muharraq Group Limited will implement policies and procedures to the standards required by the Bahrain legislation (or to any higher standard required internationally), which will:

• Identify and know its customers.
• Ensure that adequate records are kept and preserved.
• Provide training for relevant employees to enable them to understand and fulfil their obligations under the Bahrain legislation.
• Ensure suspicious transactions are reported to the Compliance Officer who will determine whether a report is to be made to the authorities and to the Bahrain Financial Intelligence Unit FIU)...
• Provide the Compliance Officer with all reasonable access to information that may be of assistance to him/her in carrying his/her duties.
• Ensure that all necessary controls and communications are in place and are operating effectively to prevent money laundering.
• This Policy should always be read and operated in conjunction with Al Muharraq Group Limited’s detailed AML/CTF and KYC procedures.

Policy Ownership

The responsibilities connected with this Policy are:

• The overall ownership of this Policy rests with Al Muharraq Group Limited’s Compliance Committee.
• The day–to-day custodian of the Policy is the Anti-Money Laundering Compliance Officer who also controls the amendments required to this Policy as a result of changing internal and external requirements.
• The Anti-Money Laundering Compliance Officer is responsible for ensuring that all Al Muharraq Group Limited’s employees comply with this Policy.

Policy Exemption

No deviations from this Policy are permitted except where formally agreed in advance with the Anti-Money Laundering Compliance Officer at the Head Office, acting in consultation with the Compliance Committee, in a documented special relaxation approved by the General Manager. This must only be considered in exceptional circumstances.

The Significance of Compliance

In addition to the criminal penalties, there is an underlying and essential reputational issue to be considered in relation to compliance represented by the considerable damage that would affect Al Muharraq Group Limited’s name and reputation by involvement in a serious money laundering incident.

Monitoring of Transactions

• Procedures were put in place to monitor customers’ transactions. The Compliance Unit generates daily and quarterly reports to achieve this task.
• Any transaction which does not fit within a customer’s transaction profile should be reviewed by the Anti-Money Laundering Compliance Officer, to determine whether the circumstances give rise to any suspicion of money laundering.
• An employee should judge a transaction to be suspicious if, in their personal judgment, they know or suspect that the transaction might be connected to any criminal offence or activity as detailed in CMA circular number 6/6/2184/19 dated 18/07/1440 H corresponding to 25/03/2019 G related to indicators of concealing the identity of true beneficiary.

Suspicious Activity Reporting

• Any employee who identifies any activity or transaction which he deems to be suspicious must report that suspicion to the Anti-Money Laundering Compliance Officer, who in his/her turn and after agreeing with the employee’s finding, will report it, through a written Suspicious Transaction Report (STR), to the FIU.
• STRs should not be discussed with anyone other than the Compliance Committee members including the customer and other staff members – to avoid the risk of “tipping off”.

Maintaining and Updating Information

• In accordance with Bahrain legislation, Money Laundering information and documents will be stored securely for at least a ten-year period. The information relating to customers (personal details, proof of beneficial ownership, etc…) should be kept up-to-date. The Compliance officer will ensure, from time to time, that detailed and concerted renewal efforts are made.

Staff Training and Communication

• The Compliance Committee has to prepare a training program on the methods of controlling financial operations, in accordance with the control procedure guide, and with other legal and regulatory texts in force.
• Ensure an ongoing training of the staff and the participation of the officers responsible for operation control and for training in relevant seminars, workshops and lectures, so that they may keep abreast of money laundering-fighting methods.
• Ensure any new material issued by the Authorities regarding combatting money laundry and terrorist financing is forwarded to all employees and training should be conducted if needed.