Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Amendment Regulations 2026

Summary

This instrument amends Bermuda's Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008 to add proliferation financing (referred to as CPF, counter-proliferation financing) as a distinct risk category alongside money laundering and terrorist financing throughout the principal Regulations. It inserts a definition of proliferation financing and CPF into regulation 2, and then systematically amends numerous other regulations and the Schedule so that references to money laundering and terrorist financing (AML/ATF) are extended to also cover proliferation financing (AML/ATF/CPF).

• Definitions: Regulation 2 is amended to insert definitions of CPF and proliferation financing, covering funds or financial services connected to CBRN weapons in contravention of Bermuda's international sanctions obligations.
• Risk assessment and controls: Regulations 6, 8, 10, 11, 12, 12A and 14A are amended so that risk assessments, policies, controls, systems, training and the AML/ATF officer functions must also address proliferation financing and counter-proliferation financing (AML/ATF/CPF).
• Sanctions cross-reference: Regulation 9 is amended to add a reference to obligations arising under the International Sanctions Act 2003 or regulations made under it.
• Reporting and record-keeping: Regulations 16, 17, 17A and 18, and the Schedule, are amended to extend existing terrorist financing references to also capture proliferation financing, including in relation to reporting and internal control provisions.

The changes are purely textual insertions extending existing AML/ATF obligations to also cover proliferation financing; they do not create new stand-alone regulations but broaden the scope of existing ones. The amendments took effect on 22 June 2026.

Key obligations

• Entities subject to the Proceeds of Crime (AML/ATF) Regulations 2008 must extend existing AML/ATF risk assessments, policies, procedures, systems and controls to also identify and mitigate proliferation financing risks.
• Compliance and AML/ATF officers must incorporate counter-proliferation financing (CPF) considerations into their functions and reporting under regulations 11, 12 and 12A.
• Reporting obligations under regulations 16 to 18 and the Schedule must now also cover suspected proliferation financing, not just money laundering and terrorist financing.
• Persons relying on regulation 9 exemptions or references must also have regard to obligations under the International Sanctions Act 2003 and regulations made under it.

Applies to

financial institutions and other persons subject to the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008

Deadlines

• 22 June 2026: Operative date on which the amendment regulations take effect.

Related documents

• This document is made under Proceeds of Crime Act 1997
• This document amends Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008
• This document is made under Anti-Terrorism (Financial and Other Measures) Act 2004