Preparing For An AML/ATF Onsite Visit From The Bermuda Monetary Authority

Key takeaways

• The Bermuda Monetary Authority conducts AML/ATF onsite supervisory visits on regulated entities across all sectors.

• It is important to be prepared for an onsite, understand the process and ensure common pitfalls are avoided. Breaches of AML/ATF requirements can and do lead to enforcement action.

• We anticipate an increased level of onsite reviews and potentially, an increase in enforcement action in the lead up to Bermuda's next mutual evaluation by the Caribbean Financial Action Task Force due to commence in 2026.

Introduction

The Bermuda Monetary Authority ("BMA") routinely conducts on-site inspections on regulated entities. These onsite visits are conducted across all financial services sectors on an increasing basis. Digital asset businesses, investment businesses, and insurance and banking sector clients need to be ready to have the AML/ATF policies, procedures, and controls in place scrutinised. If those controls are deemed