Notice to Regulated Entities on Delegation of Governor's Functions for Sanctions (2018-09-25)

Summary

This notice informs Regulated Financial Institutions (RFIs) in Bermuda that the Governor's functions relating to International Sanctions have been delegated, under the International Sanctions (Delegation of Governor's Functions) Notice 2018, to the Attorney-General and Minister of Legal Affairs. A new unit, the Financial Sanctions Implementation Unit (FSIU) within the Ministry of Legal Affairs, now acts as the administrative touch point for Targeted Financial Sanctions matters in Bermuda, replacing the Governor's office for these purposes.

• Asset freezing reports: Regulated Entities must now report the freezing of any assets to the FSIU instead of the Governor.
• Licence applications: Licence applications made pursuant to financial sanctions obligations must be submitted to the FSIU instead of the Governor.
• FSIU oversight role: The FSIU is responsible for monitoring compliance with financial sanctions regimes, assessing suspected breaches, and may refer cases to law enforcement for investigation and potential prosecution.
• Guidance available: The FSIU has published Financial Sanctions Guidance and FAQs on the government website covering International Sanctions obligations.

Regulated Entities are directed to review and update their internal policies and procedures on International Sanctions Obligations as soon as possible to reflect this delegation of functions.

Key obligations

• Report the freezing of any assets to the FSIU rather than to the Governor
• Submit licence applications made pursuant to financial sanctions obligations to the FSIU rather than to the Governor
• Review and update internal policies and procedures related to International Sanctions Obligations as soon as possible to reflect the Delegation notice

Applies to

Regulated Entities, Regulated Financial Institutions (RFIs)

Deadlines

• as soon as possible: Regulated Entities should review and update internal policies and procedures related to International Sanctions Obligations