The Assessment of Bermuda's National Money Laundering and Terrorist Financing Risk (2018-05-18)

Summary

This is Bermuda's second National Risk Assessment (NRA) of money laundering and its first assessment of terrorist financing, published by the National Anti-Money Laundering Committee (NAMLC) with input from the Bermuda Monetary Authority and other AML/ATF agencies. It is an analytical report, not a rule or directive: it describes Bermuda's legislative and institutional AML/ATF framework, identifies national money laundering threats and vulnerabilities, and assesses inherent risk sector by sector (banking, insurance, securities, money service businesses, the stock exchange, trust service providers, legal, accounting, real estate, dealers in high value goods and precious metals/stones, betting and casino gaming) as well as terrorist financing risk.

• Purpose: Provides the evidence base Bermuda uses to demonstrate a risk-based approach to AML/ATF supervision, consistent with FATF standards, following on from the 2013 assessment and a 2016 terrorist financing risk analysis.
• Content: Covers legislative framework and key agencies, regulatory and supervisory approach, transparency and beneficial ownership, international cooperation, sector-by-sector threat and vulnerability analysis, and terrorist financing threat and direction-of-funds analysis, with case study typologies in the appendices.
• Practical relevance for regulated entities: Regulated financial institutions and DNFBPs are expected to have regard to this national risk assessment when preparing their own institutional and business risk assessments and when calibrating AML/ATF controls, as required under Bermuda's AML/ATF regime.

The document itself does not create new licensing, filing, or reporting obligations; it is a risk-assessment report intended to inform supervisory priorities and to help regulated sectors understand and address their exposure to money laundering and terrorist financing risk.

Key obligations

• Regulated institutions and DNFBPs should have regard to the findings of this national risk assessment when conducting their own money laundering and terrorist financing risk assessments and when designing risk-based AML/ATF controls.

Applies to

banks, insurance companies, securities sector participants, money service businesses, Bermuda Stock Exchange participants, trust service providers, legal sector (barristers), accounting sector, real estate sector, dealers in high value goods, dealers in precious metals and stones, betting sector, casino gaming sector, charities