Corporate Policies
Blacksand Company B.S.C. © (“Blacksand” or the “Company”) is a closed joint stock company incorporated in the Kingdom of Bahrain and licensed by the Central Bank of Bahrain (“CBB”) as a Category 4 Investment Firm and primarily engaged in fund management activities.
Compliance Policy
Blacksand is committed to conducting its business with integrity, transparency, and in full compliance with all applicable laws, regulations, and regulatory standards in the Kingdom of Bahrain. Our compliance framework is designed to ensure adherence to the Central Bank of Bahrain (“CBB”) requirements (including the CBB Rulebook and relevant modules applicable to our regulated activities), as well as other applicable statutory and governance obligations.
To support this commitment, we maintain an independent compliance function led by a designated Head of Compliance with appropriate authority and access to information, records, systems, and personnel. We implement a structured, risk-based compliance monitoring program, conduct periodic reviews and targeted testing of higher-risk areas, maintain formal escalation and breach management processes, and ensure timely and accurate regulatory reporting where required.
We promote a strong compliance culture through ongoing training and awareness, and we maintain comprehensive record-keeping in line with regulatory expectations and retention requirements. Oversight of our compliance framework is supported through Board-level governance, including periodic reporting and review to ensure the continued effectiveness, independence, and resourcing of the compliance function.
AML Policy
Blacksand is committed to preventing, detecting, and reporting money laundering, terrorist financing, and proliferation financing (“ML/TF/PF”) in accordance with applicable laws and regulatory requirements in the Kingdom of Bahrain and relevant international standards. Our AML/CFT framework is aligned with the Central Bank of Bahrain Financial Crimes Module (CBB Rulebook), applicable Bahrain legislation, and internationally recognized guidance (including FATF recommendations and relevant sanctions frameworks).
We apply a risk-based approach across our business to identify, assess, and mitigate ML/TF/PF risks, considering customer, product/service, geographic, delivery-channel, and transaction risks, with periodic risk assessments conducted at least annually or upon material change.
Key measures include:
Governance & accountability: Board oversight of the AML/CFT framework, with day-to-day implementation led by the Head of Compliance & Money Laundering Reporting Officer (MLRO), supported by adequate resources and independent testing/audit.
Customer Due Diligence (CDD): Identification and verification of customers and beneficial ownership before providing services, including source of funds/wealth and purpose of relationship where applicable. Anonymous or nominee accounts are not permitted.
Enhanced Due Diligence (EDD): Additional controls for higher-risk relationships (including PEPs, non-residents/high-risk jurisdictions, complex or unusual activity, and non-face-to-face onboarding), including senior management escalation and enhanced monitoring.
Ongoing monitoring & screening: Ongoing transaction monitoring and screening against relevant sanctions and designated-party lists, with escalation of unusual activity for review.
Suspicious transaction reporting: All employees are required to promptly report suspicions to the MLRO, and the Company reports to the competent authorities in line with applicable requirements, while maintaining strict confidentiality and avoiding “tipping-off.”
Recordkeeping & training: AML/CFT records are maintained for at least five years after the end of the relationship or completion of the transaction (as applicable), and staff receive ongoing AML/CFT training appropriate to their roles.
This policy is reviewed at least annually (or earlier where required) to ensure continued effectiveness, regulatory compliance, and alignment with evolving risks and best practices
Complaints
At Blacksand, we place great importance on addressing client complaints. Our main objective is to provide you with the best possible service, leaving no room for dissatisfaction. However, we understand that issues can occasionally arise. In such cases, we want to assure you that we have established channels to allow you to express your grievances. Your feedback is invaluable to us, and we are fully committed to resolve any concerns you may have.
Complaints can be sent on the below channels:
Email: complaints@blacksand-invest.com
Tel no: +973 17 580 570 ext-115
Guide to Complaints
Complaints information
In order to investigate your Complaint, we will be relying on the information you provide us in addition to information we already hold. We may need to contact you to clarify details or request additional information. To help us investigate your Complaint swiftly and efficiently, please include the following details in your Complaint:
A-Your name and contact details including email address;
B- The name of the person at Blacksand who you have been dealing with;
C-The nature of the complaint and details of any conversation you have had with us that may be relevant to your complaint;
D-Copies of documentation which supports your Complaint;
E-Any other information that is relevant to the matter will help us investigate the matter.
Complaints Acknowledgements
All the complaints received will be acknowledged by writing to you along with a reference number within 5 working days of receiving the complaint. In case you do not receive an acknowledgment within the said period, please Contact us immediately.
Complaints Final Response (Resolution and Redress)
Following your complaint’s acknowledgment, the Company will respond in writing to your complaint within 4 weeks, explaining the position and the Company’s decision on how your complaint will be dealt with and at any point you have the right to redress your complaint. If you do not receive a resolution within the mentioned period, please tell us immediately.
Unsatisfied Complaints
If you are not satisfied with the Company’s final response, you have the right to submit your complaint case directly to the Central Bank of Bahrain (CBB), Consumer Protection Unit, within 30 calendar days from the date of receiving the Company’s final response via the following channels:
Website: Submit an online complaint form via: https://www.cbb.gov.bh/complaint-form
Telephone: Contact the Consumer Protection Office on +973 17547789
