Report of the activities of the Barristers & Accountants AML/ATF Board (the “Board”) for the year ending 31st March 2020

This report is published in accordance with Section 5(3)(b) of the Proceeds of Crime (Anti-money Laundering and Anti-terrorist Financing Supervision and Enforcement) Act 2008 (the “Act) for the calendar year ending 31st March 2020.

Click here to view the full report in .PDF format.


The most significant event of the preceding year is the successful conclusion of the Financial Action Task Force Mutual Evaluation Report (“MER”).  This process culminated in a plenary session in Antigua attended by the Supervisor, Kim Wilson.  Bermuda overall was awarded the top position worldwide for technical compliance and was among the top ten for effectiveness of supervision. That success embraced the reforms made to the rules and regulations governing the legal and accounting professions referred to in the Board’s reports from preceding years.  Those modernised rules cover entry and exit to the professions with requirement for a Fit and Proper Person certification, extended rules for compliance with AML/ATF supervisory directions, emphasised training, and required the ring-fencing of corporate administrative business (which is higher risk), among other things.  The MER, in accepting without comment the Board’s new risk-based technical regime, implicitly therefore recognises that the Board meets the technical standards expected by FATF.

As to effectiveness, general observations applicable to all Bermuda’s supervisors in the non-financial sector were made in the MER report.  They had the following nature: supervised entities to conduct self-risk analysis; focus on the filing of suspicious activity reports; supervised entities regularly to check their risk methodologies; supervisory understanding of sectoral risk; adequate staffing; training.  The Board has already implemented procedures for all these items.  In particular, the Board fully revised its supervisory framework and hired additional staff to support the Supervisor. Click here for the full report.
W. Cabral

To read the Chairman's report in its entirety please access the link above.