Please review the below statement issued by Financial Sanctions Implementation Unit of the Ministry of Legal Affairs:

Please be advised that The Cabinet Office issued a Press Release on 26 November, 2018, regarding an Advisory issued by the Minister of Legal Affairs on the 'Money Laundering and Terrorist Financing controls in higher jurisdictions: Requirement to apply Enhanced Due Diligence in higher risk jurisdictions.'  The said advisory has been posted on the Government website and can be found here.  The Minister noted that the Advisory is especially relevant to those entities that have or are considering any business relationships with the specified jurisdictions or individuals or corporate entities in such jurisdictions.

The Advisory is in response to a Financial Action Task Force (FATF) statement dated 19 October 2018, and advises regulated sectors and relevant persons to:

  1. Consider Democratic People’s Republic of Korea (DPRK) as high risk for the purposes of the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008, and apply counter measures and enhanced due diligence measures in accordance with the risks.
  1. Consider Iran as high-risk for the purposes of the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008, and apply enhanced due diligence measures in accordance with the risks.
  1. For the below jurisdictions, take appropriate actions to minimise the associated risks, which may include enhanced due diligence measures in high-risk situations:
    1. The Bahamas
    2. Botswana
    3. Ethiopia
    4. Ghana
    5. Pakistan
    6. Serbia
    7. Sri Lanka
    8. Syria
    9. Trinidad and Tobago
    10. Tunisia
    11. Yemen

 Financial Sanctions

DPRK, Iran, Syria, Tunisia and Yemen are also subject to financial sanctions in Bermuda. Therefore, regulated sectors and relevant persons also need to comply with the relevant financial sanctions measures that are set out in the respective Overseas Territories Orders for each regime.

Please note that as the nature and level of risk in the specified jurisdictions differ and it is important that the advisory and the annexes are read in their entirety.

Please see the attached document relating to the registration requirements for firms and renewal requirements for current RPFs:

Information Bulletin on RPF Registration & Renewals

A message from the Barristers & Accountants AML/ATF Board Supervisor regarding the recent Mutual Evaluation:

The Assessors have now held their closing meeting with representatives from the Government , NAMLC and the Board .  As with the interviews themselves, the tone was open and professional.  The Private Sector involvement was called out as being “forthcoming, friendly and providing all the information that was requested.  The interviews were positive, and a constructive dialogue”.

We now move into the next phase of the assessment methodology, which is the report drafting, review and finalization phase.  We expect the first draft of our report on 16th November, with our response due back by 17th December.  The assessors will then create their second draft, which will be provided both to Bermuda and to a team  of reviewers under the wider FATF umbrella, as part of FATF's process to ensure quality and consistency in these reviews.   A third draft is then produced and reviewed, which, based on current timelines for this process, would allow for the report to be presented to the CFATF Plenary next May.  Per the current schedule, Bermuda’s report could then be presented to the full FATF Plenary in October next year for subsequent finalization and publication.

It is possible that in  this  review process we may need to reach out to some of you to assist with our comments and feedback.  Thank you in advance for your assistance to ensure Bermuda continues to fully engage in this assessment process.

Please pass this message on to the other members of your respective teams who may not be copied on this email correspondence. 

Thank you all once again.

Kim N. Wilson

A new link, directing users to the Bermuda Government's National Anti-Money Laundering Committee (NAMLC) web page for International Sanctions has been added under the 'Useful Links' heading. Please ensure you staying up-to-date on the latest information published by NAMLC regarding these Sanctions.

Chairman of the Board, Mr. Warren Cabral provides an update on the matters the Board is presently working on. Click here to read it. 


Click here for our current newsletter highlighting the work of the Board as we prepare for the CFATF 2018 Mutual Evaluation.