AML-ATF Ministerial Advisory 2/2026: Money Laundering and Terrorist Financing (2026-07-24)

Summary

This is a Ministerial Advisory issued by Bermuda's Minister of Justice under the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008 (POCA Regulations), drawing the regulated sector's attention to FATF's 19 June 2026 public statements identifying jurisdictions with strategic AML/CFT deficiencies. It replaces all previous advisories on this subject and requires firms to apply enhanced due diligence measures, on a risk-sensitive basis, to business or transactions connected with the listed jurisdictions.

• Call for countermeasures: DPRK and Iran are subject to a FATF call for countermeasures (e.g. terminating correspondent relationships, limiting business with persons from these countries); both are also flagged as subject to Bermuda sanctions measures under the International Sanctions Regulations 2013.
• Call for enhanced due diligence: Myanmar is subject to a FATF call for enhanced due diligence proportionate to risk, rather than countermeasures.
• Increased monitoring (grey list): A longer list of jurisdictions (including Angola, Bolivia, Bosnia and Herzegovina, Bulgaria, Cameroon, Cote d'Ivoire, DRC, Haiti, Kenya, Kuwait, Lao PDR, Lebanon, Monaco, Nepal, Papua New Guinea, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK) and Yemen) require firms to take appropriate risk-mitigating actions, which may include enhanced due diligence.
• Delisted jurisdictions: Algeria and Namibia are noted as no longer subject to increased monitoring following FATF's assessment of their AML/CFT improvements.

The Advisory stresses that the annexed FATF statements should be read in full to properly assess risk, and that the list of higher-risk jurisdictions is not exhaustive since many countries have not yet been reviewed by FATF.

Key obligations

• Relevant persons must apply, on a risk-sensitive basis, enhanced customer due diligence to business relationships or transactions involving persons or transactions from or in jurisdictions identified by FATF as higher risk, per Regulation 11(1)(aa) and (ab) of the POCA Regulations 2008.
• Firms must apply countermeasures (e.g. terminating correspondent banking relationships, closing DPRK bank branches/subsidiaries, limiting business relationships and transactions) in relation to DPRK and Iran.
• Firms must apply enhanced due diligence measures proportionate to risk in relation to Myanmar.
• Firms must take appropriate risk-mitigating action, which may include enhanced due diligence, in relation to jurisdictions listed under increased monitoring (the grey list).
• Firms must take additional measures required under the International Sanctions Regulations 2013 for jurisdictions marked as subject to sanctions (DPRK, Iran, Bosnia and Herzegovina, DRC, Haiti, Lebanon, South Sudan, Syria, Venezuela, Yemen).
• Firms should read the annexed FATF statements in full to properly determine risk, and should not treat the listed jurisdictions as an exhaustive list of higher-risk countries.

Applies to

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

Deadlines

• October 2026: FATF will consider applying countermeasures against Myanmar if no further progress is made on its action plan by this date.