Ongoing Compliance Considerations In Bermuda's AML/ATF Regime

Continued compliance with Bermuda's anti-money laundering (AML) and anti-terrorist financing (ATF) legislation, including regulations, policies and guidance notes issued by the Bermuda Monetary Authority (the BMA or the Authority) (collectively, Bermuda's AML/ATF Regime) remains a hot topic for Bermuda regulated entities, especially those recently registered by the BMA under the newly amended Investment Business Act 2003 (the "IBA").

In April 2022 Bermuda passed the Investment Business Amendment Act 2022, which brought about fundamental changes to the IBA and resulted in a number of entities who were previously out of scope or subject to minimal exemption requirements under the Act finding themselves needing to submit an application to the Authority by 26 July 2023 in order to be formally registered or licensed under the IBA.