Regulatory and compliance in Bermuda


Created in 2018 to advise on a rapidly evolving regulatory landscape, the Bermudan regulatory group at Appleby provides clients with compliance, corporate governance, regulatory and risk advisory services, primarily on business and financial services regulation. Recently, the multi-disciplinary department (which regularly collaborates with other offices in the Caribbean) has been advising clients on economic substance compliance issues across a broad range of sectors; practice head Sally Penrose was closely involved in the  creation of the Economic Substance Task Force established by the Bermudan Minister of Finance. Other areas of focus include advising on the anti-money laundering and anti-terrorist financing regimes, as well as handling sanction compliance policies in connection with new regulatory license applications. The group also assists clients with regulatory licenses and issues arising under the Investment Business Act, the Insurance Act and the Investment Funds Act. Steven Rees Davies, who is a digital assets specialist, also has particular expertise in data protection regulations.

Practice head(s):

Sally Penrose

Other key lawyers:

Steven Rees Davies


‘The team at Appleby are knowledgeable, practical in their approach to problem-solving and make themselves very available.’


Walkers' Bermuda office has a notable track record in handling regulatory and compliance issues for a range of international and domestic financial institutions including banks, investment funds, administrators, investment managers, fintech companies, corporate service providers and insurance and reinsurance clients. Led globally by Cayman-based regulatory and risk advisory practice head Lucy Frew, the regulatory group in Bermuda is integrated into the firm's corporate practice, with particular expertise in day-to-day financial regulatory compliance work, anti-money laundering issues, international sanctions, economic substance requirements, investigations, and risk management mandates. The team is particularly active in applications to the Bermuda Monetary Authority for funds and other financial services providers. The key names to note include Natalie Neto and senior associate Melanie Fullerton, who joined the regulatory and risk advisory group in 2019.

Practice head(s):

Lucy Frew

Other key lawyers:

Natalie Neto; Melanie Fullerton


‘We feel that they are taking good care of our business, we feel comfortable, well-advised on different topics, and no need to look somewhere else. ‘

‘When you receive responses at any time of the day, and not only from 8 to 5, we know we can count on each of the advisors we are working with. The advisers we work with have always given us timely, personalised and precise responses.’

Key clients


Apollo Management

Bank of America



CVC Capital Partners

First Reserve Corporation

GSO Capital Partners

HarbourVest Partners

Oak Hill Capital Management

ASW Law Limited

ASW Law Limited primarily advises Bermuda-regulated entities on large cross-border transactions, as well as on the establishment of complex regulated structures in the funds and insurance spaces. Although primarily engaged in assisting multinational insurance groups with regulatory and compliance issues, the team also has experience in regulations affecting clients in the telecoms and digital assets sectors. Corporate practice head Neil Horner, who is assisted by counsel Hanno Tolhurst, frequently handles the regulatory aspects of large M&A and corporate transactions. The department has also seen an increase in the number of instructions relating to the economic substance and anti-money laundering regimes.

Practice head(s):

Neil Horner

Other key lawyers:

Hanno Tolhurst


‘Extremely strong on coming up with solutions to complicated corporate problems. More than any firm in Bermuda, I find them the best among firms that dig deep into the substance and then offer solutions that are based on a solid foundation; commercially savvy.’

‘Neil Horner is the best corporate lawyer for complicated corporate matters in Bermuda.’

Key clients

Covéa Mutual Insurance Group Company

McDonalds Corporation

Nayms Ecosystems Limited

Ad hoc creditor group to Digicel

Athene Life Re Ltd.

Sompo International


Alimco Re Ltd.

Daiichi Sankyo Reinsurance Limited

Mozart Insurance Ltd.

Pallas Reinsurance Company Ltd.

QBE Insurance Group

Liberty Mutual Insurance Group

Work highlights

  • Advised on all Bermuda regulatory aspects of the proposed $9bn acquisition by Covéa Mutual Insurance Group Company of the Partner Re group from EXOR.
  • Advised an ad hoc creditor group for the recently sanctioned Digicel scheme of arrangement on all Bermuda legal and regulatory aspects of the transaction, including regulatory advice in respect of the Bermuda telecoms regulatory regime and Digicel’s telecoms operating licences.
  • Advised clients on the establishment and licensing of commercial and captive (re)insurers, including advising McDonalds Corporation on all Bermuda legal and regulatory aspects of the establishment and licensing of Grand Arches Insurance Limited, a Class 2 insurer.

Carey Olsen Bermuda Limited

At Carey Olsen Bermuda Limited, a multidisciplinary team of corporate, finance, private client and dispute resolution lawyers handle the full spectrum of regulatory and compliance issues. Recently, the department has specialised in providing advice to financial services clients on economic substance and anti-money laundering issues, sanctions and anti-bribery work, data protection and privacy matters, M&A due diligence and general regulatory compliance issues, particularly in the insurance sector. Bermuda managing partner Michael Hanson has extensive experience in advising on reputational risk matters, sensitive investigations and crisis management scenarios, while senior associate Kyle Masters (who worked at the Bermuda Regulatory Authority prior to joining the firm) regularly advises clients in the finance, energy, telecoms and health sectors on their interactions with statutory bodies and regulators. Other names to note include Mary Ward, Gavin Woods and senior counsel Michael Frith, who joined the firm from Conyers in 2020.

Other key lawyers:

Kyle Masters; Michael Frith

Key clients

Bridgepoint Advisers Limited

Marsh & McLennan Companies, Inc

Ascendant Group


BF&M Limited

One Communications

Island Heritage


Bermuda Commercial Bank

Work highlights

  • Advised Bridgepoint Advisers Limited on the Bermuda regulatory aspects of the sale of Estera to Inflexion Private Equity; Estera, as part of the sale, was merged with Inflexion’s existing portfolio company Ocorian, forming a global corporate service and fund administration leader.
  • Assisted BF&M with advice relating to the Bermuda Economic Substance Act 2018 and related regulations and a corporate governance review of BF&M Limited and its Bermuda subsidiaries relating to its risk management framework and compliance.