Notice - Schedule XVIII: Schedule of AML and ATF Reporting Requirements (2016-05-02)

Summary

This is a consultation notice issued by the Bermuda Monetary Authority (BMA) proposing a new Schedule XVIII, an Anti-Money Laundering and Anti-Terrorism Financing (AML/ATF) reporting schedule for insurers writing long-term business. The Authority is seeking industry comment on the draft before finalizing it as an annual filing requirement under the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008.

The draft schedule would require in-scope insurers to complete two tables annually: Table I collects quantitative data on the insurer's exposure to money laundering/terrorist financing risk (premiums, claims, policyholder and beneficiary geographic profiles, PEP exposure, sanctions screening, suspicious activity reports, and customer due diligence practices), while Table II collects information on the insurer's AML/ATF corporate governance framework, including training, compliance officer qualifications, board oversight, and risk assessment processes.

• Scope: Applies to every insurer carrying on long-term business, excluding any reinsurance business of a long-term insurer.
• Purpose: Data will feed the Authority's risk-based AML/ATF supervision and inform preparation for Bermuda's AML/ATF Mutual Evaluation scheduled for Q1 2018.
• Origin: Builds on an October 2015 AML/ATF data call previously circulated to licensed insurers.
• Consultation status: The schedule is a draft posted for industry consultation and is not yet in force; comments were invited before finalization.

As a draft consultation document, this notice does not itself impose binding filing obligations, but it signals BMA's intent to require affected insurers to file the completed Schedule XVIII annually once adopted.

Key obligations

• Insurers carrying on long-term business would be required to complete and file Table I and Table II of Schedule XVIII annually, covering AML/ATF risk exposure and governance data, once the schedule is finalized.
• Interested parties (insurance industry and other stakeholders) were invited to submit comments on the draft schedule to policy@bma.bm no later than 27 May 2016.

Applies to

insurers carrying on long-term business (excluding reinsurance business of long-term insurers)

Deadlines

• 27 May 2016: Deadline for interested persons to submit comments on the draft AML/ATF Schedule XVIII to policy@bma.bm