NAMLC Consultation Paper - Proposed Amendments to the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008 to incorporate Proliferation Financing (PF) Risk Assessment and Mitigating Measures (2026-01-28)

Summary

This is a NAMLC (National Anti-Money Laundering Committee) consultation paper proposing amendments to Bermuda's Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008. The proposals would add proliferation financing (PF) risk assessment and mitigation requirements to align with the FATF's revised Recommendation 1, following Bermuda's first PF National Risk Assessment completed in 2025. The changes are still at draft/consultation stage and are not yet in force.

• New definitions: Introduces definitions of proliferation financing and counter proliferation financing (CPF) into the Regulations, which currently contain none.
• PF risk identification and assessment: Would require AML/ATF regulated entities to document their PF risk assessments, keep them up to date, and have mechanisms to provide this information to competent authorities and self regulated bodies.
• PF risk mitigation: Would require entities to adopt senior management approved policies, controls and procedures to manage and mitigate identified PF risks, monitor and enhance these controls, and apply proportionate measures depending on whether PF risk is assessed as higher or lower.
• Consequential regulation changes: The annexed drafting extends existing customer due diligence, timing of verification, reporting officer, independent audit function, and training obligations to expressly cover proliferation financing alongside money laundering and terrorist financing.

NAMLC is inviting industry feedback on the proposed amendments; the changes would apply to the full range of Bermuda's AML/ATF regulated entities once finalised and brought into force.

Key obligations

• Interested parties must submit written comments and feedback on the proposed amendments to info-NAMLC@gov.bm no later than February 11, 2026.

Applies to

AML/ATF regulated financial institutions (including Digital Asset Businesses), independent professionals (lawyers and accountants), casino operators, dealers in high value goods, real estate brokers and real estate professionals

Deadlines

• February 11, 2026: Deadline for industry stakeholders to submit written comments and observations on the proposed amendments to info-NAMLC@gov.bm.

Related documents

• This document amends Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008