What Financial Institutions and DNFBPs Need to Know

Preparing for Bahrain's 2026 FATF Mutual Evaluation

The Financial Action Task Force (FATF) is the global authority on anti-money laundering and counter-terrorist financing (AML/CFT). It sets international standards through its 40 Recommendations, which guide countries in building effective legal, regulatory, and operational frameworks to combat financial crime. As Bahrain prepares for its 2026 FATF Mutual Evaluation, financial institutions, DNFBPs, fintechs, and corporates must align with the Financial Action Task Force (FATF)'s enhanced evaluation methodology. This briefing note unpacks what evaluators will look for in 2026, key findings from Bahrain’s last assessment, and how institutions can build effective AML/CFT systems that withstand regulatory scrutiny.

Summary
Introduction
  • Bahrain’s Commitment to AML/CFT Excellence

  • The Role of the Private Sector in Financial Crime Prevention

FATF Findings
  • 2018 FATF Mutual Evaluation

  • 2022 Enhanced Follow-up Report

  • Identified Shortcomings and Areas for Improvement

AMAN | A Government-Backed AML/CFT Solution
  • Features and Capabilities

  • Role in Supporting Private Sector Compliance

The Legal Requirement to Report Suspicious Activity
  • Legislative Decree No. 4 of 2001

  • Legal Obligations for Businesses

The Importance of Reporting Suspicious Activity
  • The Role of Suspicious Transaction Reports (STRs)

  • Impact on National Security and Law Enforcement

Best Practices for Submitting STRs
  • Key Components of a Good STR Report

  • Content and Formatting Tips

  • Ensuring Compliance and Confidentiality

Post-Reporting Process
  • Risk Classification and Enhanced Due Diligence

  • Business Actions After Submitting an STR

The Costs of Getting it Wrong
  • Case Studies of Non-Compliance

  • Legal and Financial Consequences

About Themis
Introduction

The FATF’s 5th Round places greater weight on real-world outcomes over written policies. Bahraini companies must now show that their AML/CFT frameworks are not only in place, but actively reducing financial crime risk through risk-based controls, effective CDD/EDD, STR filings, and beneficial ownership tracking.Emerging threats—like cybercrime, sanctions evasion, and misuse of technology—will be a core focus, alongside regional support from MENAFATF to enhance compliance across MENA. Preparation must include updated policies, training, audits, and governance.

Aman is playing a key role in helping companies prepare for the upcoming FATF evaluation by ensuring their compliance with all AML obligations and safeguarding their businesses against financial crime. This includes helping institutions conduct robust risk assessments, design tailored onboarding and EDD procedures, automate STR filings, enhance BO transparency, and build systems that stand up to international scrutiny.

What’s Inside the Briefing Note

1. A clear overview of the FATF Mutual Evaluation Framework, including technical compliance and effectiveness standards.
2. Breakdown of the FATF 40 Recommendations and 11 Immediate Outcomes (IOs).
3. Deep dive into Bahrain’s legislative framework and past evaluation results.
4. Practical private sector responsibilities under the FATF methodology.
5. Insights into MENAFATF’s role in regional AML/CFT supervision.
6. Strategic guidance to support institutional readiness ahead of the 2026 assessment.
7. A checklist of compliance documents mapped to FATF requirements.

Why This Matters for Bahrain

FATF evaluations are high-stakes assessments that influence:

  • Global financial reputation.

  • Investor and correspondent banking confidence.

  • Access to international markets.

  • Bahrain’s 5th Round Evaluation will apply stricter effectiveness metrics, shorter review cycles, and deeper scrutiny of private sector engagement — including risk-based controls, beneficial ownership transparency, and STR quality.

Sample Pages

This guide offers a comprehensive roadmap to help you navigate regulatory requirements, improve risk management, and enhance your organisation’s financial crime prevention efforts. Please complete the below form to download the full report.

Download Report Here

Themis International Services Ltd is committed to protecting and respecting your privacy, and we’ll only use your personal information to administer your account and to provide the products and services you requested from us. From time to time, we would like to contact you about our products and services, as well as other content that may be of interest to you. If you consent to us contacting you for this purpose, please tick below to say how you would like us to contact you:

In order to provide you the content requested, we need to store and process your personal data. If you consent to us storing your personal data for this purpose, please tick the checkbox below.

You may unsubscribe from these communications at any time. For more information on how to unsubscribe, our privacy practices, and how we are committed to protecting and respecting your privacy, please review our Privacy Policy.

Thank you.  
Your details have been received.    
The following items are available for download:
That didn't work. Please check you've completed all necessary fields.