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New compliance and regulatory updates for Bermuda

19 January 2023

Read our latest regulatory and compliance update focusing on Bermuda by Rebecca Holloway.

December 2022:

  • BMA - Financial Sanctions Updates (https://www.bma.bm/international-sanctions)
    • Financial sanctions updates have been published by the BMA for Russia, Mali, Iran (Human Rights), Global Anti-Corruption, Global Human Rights, Myanmar, South Sudan and Haiti.
    • The Haiti (Sanctions) (Overseas Territories) Order 2022 and The Haiti (Sanctions) Regulations 2022 came into force on December 28, 2022.
    • Note: The Haiti (Sanctions) (Overseas Territories) Order 2022 applies to all British Overseas Territories, except for Bermuda and Gibraltar, which implement sanctions under their own legislative arrangements.
  • BMA - Anti‐Money Laundering/Anti‐Terrorist Financing (AML/ATF) Data Call (for AFSL, AIFSL & ACSL)
    • The BMA is enhancing the annual AML/ATF Data Call submission process via a web‐based portal, which requires dual‐factor authentication and includes database encryption to advance efficiency and efficacy. This should also eliminate accessibility issues.
    • In January 2023, the Authority will issue the Section 16 Notice along with the web‐based portal access instructions to registered entities that are required to complete the annual AML/ATF data call questionnaire under Section 16 of the Proceeds of Crime (Anti‐Money Laundering and Anti‐Terrorist Financing Supervision and Enforcement) Act 2008.
    • No new requests will be added to the data call questionnaire this year.
    • Any questions relating to the reporting update or contact detail changes should be directed to amlresearch@bma.bm.
    • The deadline for submissions will be 31 March 2023.


Deadlines for Q1 2023: 

  • Within 20 business days after each month-end: NAV Filings (BMA)
  • January 31, 2023: Government Fees and Annual Declarations/Returns for Exempted Companies (RoC)
  • March 31, 2023: BMA Fees
  • March 31, 2023: AML/ATF Data Call (for the BMA) – date confirmed by the BMA in Dec. 2022


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