• Helping organizations assess their money laundering and terrorist financing risks and documenting that assessment within a business risk assessment;
• Performing AML/ATF compliance gap analysis against regulatory requirements and better practices;
• Conducting AML/ATF compliance ‘health checks’ and independent reviews of AML/ATF compliance programmes;
• Supporting internal audit teams complete AML/ATF testing;
• Designing and updating AML/ATF policies and procedures;
• Creating up front and ongoing customer due diligence processes;
• Undertaking integrity due diligence of customers, employees, suppliers and company acquisition targets;
• Developing and delivering tailored AML/ATF training; and
• Investigating instances of money laundering and terrorism financing.

In Bermuda a “AML/ATF regulated financial institution” means a person who:

• carries on deposit-taking business within the meaning of section 4 of the Banks and Deposit Companies Act 1999;
• carries on investment business within the meaning of section 3 of the Investment Business Act 2003;
• is an insurer (and not a reinsurer) registered under section 4 of the Insurance Act 1978 who carries on long term business falling within paragraph (a) or (c) of the definition of “long-term business” in section 1(1) of the Insurance Act 1978;
• is an insurance manager or broker registered under section 10 of the Insurance Act 1978 in so far as he acts as a manager or broker in connection with long term business (other than reinsurance business) falling within paragraph (a) or (c) of the definition of “long-term business” in section 1(1) of the Insurance Act 1978;
• carries on the business of a fund administrator within the meaning of section 2(2) of the Investment Funds Act 2006;
• carries on money service business within the meaning of section 20AA of the Bermuda Monetary Authority Act 1969;
• carries on trust business within the meaning of section 9(3) of the Trusts (Regulation of Trust Business) Act 2001 and is not otherwise exempted by or under paragraph 3 of the Trusts (Regulation of Trust Business)Exemption Order 2002;
• is the operator of an investment fund within the meaning of section 2 of the Investment Funds Act 2006; or
• carries on corporate service provider business within the meaning of section 8 of the Corporate Service Provider Business Act 2012.

The Bermuda Monetary Authority is the AML/ATF regulator of
financial institutions in Bermuda and they have issued guidance notes for
financial institutions which are provided below. If you have any questions or
would like to learn more please give us a call. 

AML/ATF for Registered Charities in Bermuda

• The Charities (Anti-Money Laundering. Anti-Terrorist Financing and Reporting) Regulations 2014 came into effect on December 17, 2014 and require all Registered Charities to designate an AML/ATF compliance officer, conduct due diligence, train relevant officers, put in place AML/ATF systems and controls, keep records and complete all reporting requirements. If you have any questions or would like to learn more please give us a call.

AML/ATF for Accountants and Lawyers in Bermuda

• The Barristers and Accountants AML/ATF Board (“the Board”) is a statutory board established jointly by the Institute of Chartered Accountants of Bermuda (“ICAB”) and the Bermuda Bar Association. The Board has been designated by the Minister of Justice under the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing Supervision and Enforcement) Act, 2008 (the “Act”) to be the supervisory authority for regulated professional firms (barristers and accountants) as defined in the Act.
• Further details can be found on the Barristers and Accountants AML/ATF Board website at www.amlatfboard.bm. If you have any questions or would like to learn more please give us a call.

AML/ATF for High Value Dealers in Bermuda

• The Financial Intelligence Agency (FIA) is the regulator for the High Value Dealers in Bermuda. If you have any questions or would like to learn more please give us a call.