Notice - New Policy Implementation - Police Clearance Certificate Requirement for Key Persons (2026-08-13)

Summary

This BMA notice announces a new policy requiring Police Clearance Certificates for 'Key Persons' being vetted in connection with AML/ATF regulated financial institutions (AML/ATF RFIs). It takes effect on 1 October 2026 and applies to new applications and to notifications of changes to Key Persons.

• Who is a Key Person: Any person subject to the fit and proper assessment under the Minimum Criteria for Licensing or Registration in the relevant Regulatory Acts (e.g. Insurance Act, Banks and Deposit Companies Act, Digital Asset Business Act, Trusts Act, Investment Business Act, Fund Administration Provider Business Act, Investment Funds Act, Credit Unions Act, Money Service Business Act).
• Recency: The Police Clearance Certificate must be no more than twelve months old at the time of submission.
• Jurisdictional scope: A Certificate is required from each country where the individual was ordinarily resident for more than six months at any time in the previous three years.
• Alternative documentation: Where a Certificate cannot be obtained from a relevant jurisdiction, the Authority may accept substitute documentation on a case by case basis.
• Transition treatment: Applications received in full before 1 October 2026 will not be subject to this requirement; those submitted on or after that date must include the Certificate where applicable.

The Authority will update application guidance and forms accordingly and encourages stakeholders to prepare early to avoid delays. Questions should be directed to aml@bma.bm.

Key obligations

• From 1 October 2026, any person being vetted by the BMA as a Key Person for an AML/ATF regulated financial institution must submit a Police Clearance Certificate with their personal declaration form.
• The Certificate must be no more than twelve months old at the time of submission.
• Applicants must provide a Certificate from each country where the Key Person was ordinarily resident for more than six months at any time during the previous three-year period.
• Where a Certificate cannot be obtained, the applicant must provide appropriate substitute documentation acceptable to the Authority.
• Stakeholders must include the required Certificate documentation for applications or change-of-Key-Person notifications submitted on or after 1 October 2026.

Applies to

AML/ATF regulated financial institutions, banks and deposit companies, insurers, digital asset businesses, corporate service providers, trust businesses, investment businesses, fund administration providers, investment funds, credit unions, money service businesses, applicants and Key Persons subject to fit and proper vetting

Deadlines

• 1 October 2026: Effective date from which applications or notifications involving AML/ATF RFI Key Person vetting must include a Police Clearance Certificate.
• twelve (12) months: Maximum age of the Police Clearance Certificate at time of submission.
• previous three-year period (more than six months residency): Period used to determine which jurisdictions require a Certificate.