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CBB Rulebook Volume 1 Conventional Banks (Financial Crime Module)

The Financial Crime Module of the Central Bank of Bahrain’s Rulebook Volume 1 establishes AML/CFT obligations for all conventional bank licensees. It integrates FATF recommendations and serves as the operational framework for implementing both local AML legislation (notably Decree Law No. 4 of 2001) and WTR-aligned standards. It covers all areas relevant to wire transfers, including customer due diligence, monitoring, record-keeping, and the handling of electronic fund transfers.


Wire Transfer Obligations

Chapter FC-3 outlines specific obligations for wire and electronic transfers. All outward wire transfers must include complete originator and beneficiary information. This includes full name, account number or IBAN, address or identification number, and date and place of birth where relevant. Cross-border batch files must also be traceable by transaction reference numbers. If originator information is missing from an incoming transfer, the beneficiary bank is required to treat the transaction as potentially suspicious and escalate it to the MLRO.


Intermediary banks are responsible for retaining wire transfer data and are required to have procedures to identify and address transactions lacking originator or beneficiary information. These requirements are consistent with the WTR’s emphasis on preserving traceability throughout the transfer chain.


Customer Due Diligence & Monitoring

The Rulebook mandates comprehensive due diligence for all transactions involving wire transfers, regardless of amount. Conventional banks must verify the identity of originators and beneficiaries, the purpose of the business relationship, and the source of funds. Non-resident and high-risk clients must undergo enhanced due diligence, including regular profile reviews and transaction monitoring.


Digital onboarding and non-face-to-face services are addressed through mandatory verification technologies and safeguards against impersonation, reinforcing the integrity of digital value transfers. Enhanced due diligence also applies to politically exposed persons, pooled funds, and accounts introduced via intermediaries.


Record-Keeping & Access

All customer identification and transaction documentation, including STRs and MLRO assessments, must be retained for a minimum of five years. The Rulebook also requires that all such records be made available promptly to competent authorities. These practices are foundational to WTR compliance, particularly for reconstructing transaction trails and supporting financial investigations.


MLRO Oversight & Reporting

The Money Laundering Reporting Officer (MLRO) holds responsibility for reviewing all suspicious transactions and reporting confirmed cases to the Financial Intelligence Directorate and CBB via an electronic STR system. The Rulebook sets strict conditions for tipping-off prohibitions, further aligning with WTR mandates on confidentiality and non-interference with investigations.


Annual compliance reviews, transaction monitoring audits, and internal reporting frameworks must be documented and reported to senior management and the CBB. These internal governance obligations ensure that WTR implementation is not only operational but also subject to regular oversight.


International Transfers & MVTS

The Rulebook prohibits transfers to or from unauthorised money or value transfer service (MVTS) providers and mandates due diligence on all remittances made via authorised MVTS agents. Where MVTS providers control both the sending and receiving ends, they are required to assess transactions holistically and file STRs in all relevant jurisdictions. These provisions directly reinforce the cross-border compliance imperatives of the WTR.


Conclusion: WTR Compliance Integration

The Financial Crime Module under the Central Bank of Bahrain’s Rulebook Volume 1 operationalises WTR principles across the banking sector. It requires full traceability of both domestic and cross-border fund transfers through stringent due diligence, data retention, and monitoring requirements. The framework also promotes international regulatory cooperation and transparency in wire transfers, including those involving digital and correspondent channels. Together with Bahrain’s broader AML legislation, this Rulebook ensures a robust and WTR-aligned compliance posture for conventional banks operating within or from the Kingdom.

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