Dear Ladies and Gentlemen,

I became Chairman of the Board in January 2016 and since then the Board has had a very busy 9 month period.   With the approaching Mutual Evaluation to occur in 2018 and the gearing up of the National Anti Money Laundering Authority- NAMLC- preparing the Nation for this visit,  a lot has been asked of our organization.  This is a very important review which will have a large impact on our Nation so we are fully engaged in this preparation, not only for this agency but for Bermuda as a whole.

In 2018 Bermuda will be assessed by CFATF on two levels in the AML/ATF space: Technically do we have all the laws and policies in place to supervise AML and ATF compliance.   Our Effectiveness will also be measured and this is more about how much all our sectors are aware of the risks of Money Laundering and Terrorist Financing and how they are mitigated in the space.  As such we have had to design and implement new tools to help us think about these matters and to improve our Effectiveness.   Along with this has come a huge engagement project with all the other AML/ATF supervisors in Bermuda who are all meeting on a regular basis to prepare Bermuda for this audit.

We have increased our outreach efforts and training programs as provided by our Supervisor.  Going forward joint barrister and accountant training sessions will occur and think tank sessions of the MLROs will be hosted – the first one occurring on November 24 2016.     Our Supervisor has completed OnSite visits of almost all our regulated entities so we now have a strong touch point with the sector we regulate and have shared a lot of information and direction with our regulated entities.   

We have started to collect data from the RPFs to start to measure our Effectiveness as a supervisory authority.   Your feedback and input to this data gathering which will be ongoing is most important as our Effectiveness will be measured over a period of time.   We have met with the Boards of the Bar Association and CPA and have shared the vision of the compliance effort and the way the preparation for the Mutual Evaluation is being managed.   We have conducted an Enterprise risk assessment of our sector and our environment and in October we conducted a deep dive risk assessment of all our RPFs.   From this we have generated an RPF rating scheme and a Compliance program where we expect to focus more on looking at RPF Risk Assessments and Mitigating Tools.  

We are pleased to be able to launch a new website which will be a helpful tool to be able to provide information to the sector and to allow for interaction as needed.   We welcome questions and engagement so that the task of managing compliance around the AML /ATF legislation is robust and clear.

With Regards,

Christine Patton -  Chairman