AML-ATF Ministerial Advisory 1/2026: Money Laundering and Terrorist Financing (2026-02-24)

Summary

This is a Ministerial Advisory issued by Bermuda's Minister of Justice (published via the BMA) drawing the regulated sector's attention to the FATF's 13 February 2026 public statements on jurisdictions with strategic AML/CFT deficiencies. It reminds relevant persons of their existing obligation under Regulation 11(1)(aa) and (ab) of the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008 (POCA Regulations) to apply enhanced customer due diligence, on a risk-sensitive basis, to customers and transactions connected to higher-risk countries identified by FATF or CFATF.

• Black-listed jurisdictions (apply countermeasures/EDD): DPRK, Iran and Myanmar are subject to a FATF call for countermeasures (DPRK, Iran) or proportionate enhanced due diligence (Myanmar).
• Grey-listed jurisdictions (consider higher risk): Algeria, Angola, Bolivia, Bulgaria, Cameroon, Cote d'Ivoire, Democratic Republic of the Congo, Haiti, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Namibia, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK) and Yemen are flagged for consideration of enhanced due diligence and appropriate risk mitigation.
• Sanctions overlay: Jurisdictions marked with an asterisk (DPRK, Iran, Myanmar, DR Congo, Haiti, Lebanon, South Sudan, Syria, Venezuela, Yemen) are also subject to sanctions measures under the International Sanctions Regulations 2013, requiring additional measures.
• Superseding effect: This Advisory replaces all previous Ministerial Advisories issued on this subject.

The Advisory applies to all entities and persons covered by Regulation 4 of the POCA Regulations, and firms are told they must comply with the guidance in implementing their financial crime systems and controls. The lists are not exhaustive, since many jurisdictions have not yet been reviewed by FATF, so relevant persons must still exercise judgment on other higher-risk countries.

Key obligations

• Apply enhanced customer due diligence, on a risk-sensitive basis, to customers or transactions from or in jurisdictions identified by FATF/CFATF as higher risk, per Regulation 11(1)(aa) and (ab) of the POCA Regulations.
• Apply FATF-mandated countermeasures (e.g. terminating correspondent relationships, closing subsidiaries/branches, limiting business relationships) in relation to DPRK and Iran.
• Apply enhanced due diligence proportionate to risk in relation to Myanmar.
• Consider and apply appropriate risk mitigation measures, including possible enhanced due diligence, for the listed 'grey list' jurisdictions.
• Apply additional measures under the International Sanctions Regulations 2013 for jurisdictions marked as subject to sanctions.
• Read the annexed FATF statements in full to properly assess and determine risk relating to the listed jurisdictions.

Applies to

AML/AFT regulated financial institutions, independent professionals, casino operators, dealers in high value goods registered with the FIA, real estate brokers and real estate agents

Deadlines

• 24 February 2026: Date the Advisory was issued and takes effect, replacing all previous advisories on this subject.
• June 2026: FATF will consider applying countermeasures to Myanmar if no further progress is made on its action plan by this date.