Bahrain – CM P – Update 2021

Apr 13, 2021

Country Manual Products – 

We would like to inform you that BRP has reviewed and updated the BEHAVIOUR TEMPLATE (4th Edition 2020; minor amendment of the structure), the DEFINITIONS & CONCEPTS and the REGULATORY OVERVIEW for the following

COUNTRY MANUAL PRODUCTS:

BAHRAIN (BH)

Please note the following material changes regarding the above-mentioned jurisdiction:

  • Based on a new interpretation of the local laws and considering market practices, for foreign (unlicensed) service providers, the locally applicable distinction between different types of investors is no longer deemed of relevance. The category of “Other Investors” has therefore been deleted in the Behaviour Template.
  • It has been highlighted that the provision of Investment Research & Financial Analysis to local investors is generally not deemed “distribution” provided that both the issuer and the provider of the documents are in no way related/connected/associated to/with the analysed company nor receive any kind of inducements from the latter or any other person.
  • For consistency purposes and in alignment with the Country Manual Private Banking, any provision of investment services (including Investment Research & Financial Analysis) on Bahraini territory (at target) without the presence of a written “advisory agreement” is not permitted. Accordingly, the Behaviour Template now provides the answer “NO” for all financial products distributed in these scenarios.

Should you have any questions, please do not hesitate to contact us.

Best regards,