AML-ATF Ministerial Advisory 3/2025: Money Laundering and Terrorist Financing (2025-12-16)

Summary

This Ministerial Advisory from Bermuda's Minister of Justice draws the attention of the AML/ATF regulated sector to the latest FATF public statements (24 October 2025) identifying jurisdictions with strategic deficiencies in their anti-money laundering and counter-terrorist financing regimes. It replaces all previous advisories on this subject and directs relevant persons to apply enhanced due diligence, and in some cases counter-measures, when dealing with customers or transactions connected to the listed high-risk jurisdictions, in line with Regulation 11(1)(aa) and (ab) of the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008.

• Apply counter-measures and enhanced due diligence: DPRK, Iran and Myanmar are identified as high-risk jurisdictions subject to a call for action; firms should treat them as high risk and apply counter-measures and enhanced due diligence in accordance with the associated risks.
• Take appropriate risk-based action: A longer list of jurisdictions under increased monitoring (the grey list), including Algeria, Angola, Bolivia, Bulgaria, Cameroon, Cote d'Ivoire, Democratic Republic of the Congo, Haiti, Kenya, Lao PDR, Lebanon, Monaco, Namibia, Nepal, South Sudan, Syria, Venezuela, Vietnam, Virgin Islands (UK) and Yemen, requires firms to take appropriate action to minimise associated risks, which may include enhanced due diligence in high-risk situations.
• Sanctions overlay: Jurisdictions marked with an asterisk (DPRK, Iran, Myanmar is not marked but Democratic Republic of the Congo, Haiti, Lebanon, South Sudan, Syria, Venezuela, Yemen are marked) are also subject to sanctions measures under the International Sanctions Regulations 2013, requiring additional measures beyond enhanced due diligence.
• Read annexes in full: Firms are advised to read the full FATF statements at Annex A (call for action list) and Annex B (increased monitoring list) to properly assess and determine the risks relating to each jurisdiction.
• Non-exhaustive list: Firms are reminded that many jurisdictions have not yet been reviewed by FATF, so the lists are not exhaustive of jurisdictions that may present higher money laundering or terrorist financing risk.

The advisory applies to all entities and persons subject to the POCA Regulations under Regulation 4: AML/ATF regulated financial institutions, independent professionals, casino operators, dealers in high value goods registered with the FIA, and real estate brokers and agents. It is an informational/advisory notice implementing an existing regulatory obligation rather than creating a new standalone filing requirement.

Key obligations

• Relevant persons must apply enhanced customer due diligence, on a risk-sensitive basis, to business relationships and transactions connected with jurisdictions identified by FATF or CFATF as higher risk, per Regulation 11(1)(aa) and (ab) of the POCA Regulations 2008.
• Firms must consider DPRK, Iran and Myanmar as high risk and apply counter-measures and enhanced due diligence measures commensurate with the risk.
• Firms must take appropriate action, which may include enhanced due diligence, in relation to jurisdictions on the FATF increased monitoring (grey) list.
• Firms dealing with sanctioned jurisdictions marked with an asterisk must apply additional measures required under the International Sanctions Regulations 2013.
• Firms should read the full annexed FATF statements to properly assess jurisdiction-specific risks before determining the appropriate response.

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