Bahrain – CM P

2024, Cross-border, Update

Country Manual Products – Bahrain BRP Update 2024

BRP has updated its Country Manual Products for Bahrain

Source of changesAnswers
Law / RegulationNo
New Position of the AuthoritiesNo
Evolution of Expert’s InterpretationYes

Definitions & Concepts, Regulatory Overview and Behaviour Template

The Country Manual has been reviewed to ensure that the content of all the documents remains accurate and up to date.

Material changes

The changes/modifications are as follows:

  • In alignment with the Country Manual Private Banking (CM PB), the provision of Macroeconomic information/reports is now only permitted on an occasional basis onshore in Bahrain (at target).
  • In addition, investment research and financial analysis documents/reports as well as the provision of publications and other marketing materials are no longer permitted on an active cross-border basis into Bahrain (remote) without/outside the scope of a written advisory agreement (spot advice).
  • As a reminder, the active provision of investment advice based on a written advisory agreement requested at the initiative of the investor and covering the relevant financial services/products does not trigger the “local distribution rules” and is a “current market practice” of foreign (unlicensed) service providers. To better reflect the current interpretation of the regulatory framework, the CM P BT provides the answer “Grey Zone/YES” – If the asset class is covered by the advisory agreement”.

Non-material changes

Some comments and contents have been redrafted in the CM without introducing substansive changes to better reflect the evolving interpretation of the regulatory framework.

  • To better reflect the approach to the distribution of registered and unregistered funds, some specific funds targeting different types of clients have been streamlined (e.g. “expert CIUs”).

For more information, please contact us: info@brpsa.com

Geneva, April 15th 2024