WWL: Have there been any major changes or developments in your
jurisdiction over the past 12–18 months? How have these
impacted your practice?
RAS: In August 2016, the Bermuda Monetary
Authority (BMA) issued the Insurance Manager Code of Conduct
requiring insurance managers to follow a set of procedures when
carrying out their functions.
In September 2017, the Bribery Act 2016 became operative
creating offences that apply to Bermuda individuals or corporate
entities conducting business in or outside Bermuda and non-Bermuda
individuals or corporate entities conducting business in
Bermuda.
In March 2017, the AML/ATF Regulations were amended, expanding
the duty on AML/ATF regulated financial institutions to act in
circumstances where AML/ATF activity is suspected.