AML/ATF Information Form

Summary

This is a BMA information collection form used to gather AML/ATF compliance details from Bermuda registered and authorised investment funds. It is issued under the Proceeds of Crime (Anti-Money Laundering/Anti-Terrorist Financing) Regulations 2008 and is used when the Authority conducts periodic AML/ATF assessments of a fund.

• Business information: Entity name, class of fund under the Investment Funds Act 2006 (Sections 6, 6A, 7, 8B or 11), fund operator and fund administrator names.
• AML/ATF policies: Confirmation of whether AML/ATF policies and procedures are attached, or a stated reason if not, and whether the fund invests in digital assets.
• Compliance and reporting officers: Name, contact details, address and resume for the Compliance Officer responsible for AML/ATF oversight and the Reporting Officer who receives internal suspicious activity reports.
• Company details: Physical and mailing address of the company, and details of the person completing the form.

The form itself does not set a standing filing deadline; it is completed and submitted when a fund is selected by the BMA for a periodic AML/ATF assessment, at which point the Authority requests the required information.

Key obligations

• A fund selected for periodic BMA AML/ATF assessment must complete and submit this Information Form when requested by the Authority
• The fund must attach its AML/ATF policies and procedures, or state the reason if they are not attached
• The Operator of the fund must consider the inherent risks associated with the fund's activities in determining appropriate AML/ATF controls
• The form requires designation of a Compliance Officer and a Reporting Officer with contact details and attached resumes

Applies to

Authorised funds (Institutional, Standard, Administered) under Investment Funds Act 2006 Section 11, Registered private funds under Investment Funds Act 2006 Section 6, Registered Professional Class A Funds under Section 6A, Registered Professional Class B Funds under Section 7, Registered Professional Closed Funds under Section 8B, Fund operators, Fund administrators