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.