AML/ATF Ministerial Advisory 2/2025: Money Laundering and Terrorist Financing controls in higher risk jurisdictions (2025-07-17)

Summary

This is Ministerial Advisory 2/2025, issued by Bermuda's Minister of Justice, drawing attention to the June 2025 FATF public statements identifying jurisdictions with strategic AML/CFT deficiencies. It reminds the regulated sector and 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 to apply enhanced due diligence on a risk-sensitive basis to higher-risk jurisdictions, and replaces all prior advisories on this topic.

• Call for action list (black list): DPRK, Iran and Myanmar are identified as high-risk jurisdictions; firms should consider countermeasures and enhanced due diligence in accordance with the associated risks.
• Increased monitoring list (grey list): Algeria, Angola, Bolivia, Bulgaria, Burkina Faso, Cameroon, Cote d'Ivoire, Democratic Republic of the Congo, Haiti, Kenya, Lao PDR, Lebanon, Monaco, Mozambique, Namibia, Nepal, Nigeria, South Africa, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK) and Yemen are named; firms should take appropriate actions to minimise associated risks, which may include enhanced due diligence in high risk situations.
• Sanctions overlap: Jurisdictions marked with an asterisk (DPRK, Iran, Myanmar exceptions vary by annex; specifically DPRK, Iran, Democratic Republic of the Congo, Haiti, Lebanon, South Sudan, Syria, Venezuela and Yemen as listed) are also subject to sanctions measures requiring additional measures under the International Sanctions Regulations 2013.
• Scope of application: The advisory applies to all entities and persons subject to Regulation 4 of the POCA Regulations: AML/ATF regulated financial institutions, independent professionals, casino operators, dealers in high value goods registered with the FIA, and real estate brokers and agents.

The advisory does not itself create new legal requirements beyond the existing POCA Regulations, but operationalises the enhanced due diligence obligation by identifying the specific jurisdictions currently flagged by FATF. Firms are cautioned that the list is not exhaustive, since many jurisdictions have not yet been reviewed by FATF.

Key obligations

• Relevant persons and the regulated sector must apply enhanced customer due diligence, on a risk-sensitive basis, to business relationships or transactions involving DPRK, Iran and Myanmar, including considering countermeasures where appropriate.
• Relevant persons and the regulated sector must take appropriate actions to minimise risks associated with the listed grey-list jurisdictions, which may include enhanced due diligence in high risk situations.
• Firms must consider the FATF assessments in Annexes A and B, read in their entirety, when determining risk in their AML/CFT systems and controls.
• Firms dealing with jurisdictions marked as subject to sanctions measures must take additional measures in accordance with the International Sanctions Regulations 2013.

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