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Regulatory updates for Bermuda for January 2023

28 February 2023

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

 January 2023:

  • BMA - 2023 Business Plan (Business Plan - BMA)
    • Highlights in the 2023 BMA roadmap include plans for the following:
      • Further positioning its human resources to skillfully deal with the complexities of emerging infrastructures, products and technologies
      • Strengthening the anti-money laundering/anti-terrorist financing supervisory data call approach, namely through further automation and data collection, analysis and presentation enhancements
      • Ongoing work and multi-year priorities, including the continued build-out of the conduct of business regime and ESG standards across sectors, greater use of technology in supervision and operations, maintained commitment to supervising entities’ operational resilience, and enhancements to the regulatory framework


  • Digital Assets
    • BMA - Accounting treatment for digital assets stored or maintained by Digital Asset Businesses - Notices (bma.bm)
      • For Digital Asset Business (“DAB”) entities that store or maintain digital assets on behalf of their customers, the relevant assets and liabilities shall be presented on the DAB’s statutory balance sheet and be subject to audit
      • For any questions regarding this matter, please contact Fintech@bma.bm


  • Article & Order published by FinCEN re: Virtual Currency Exchange Bitzlato Limited

(FinCEN Identifies Virtual Currency Exchange Bitzlato as a “Primary Money Laundering Concern” in Connection with Russian Illicit Finance | FinCEN.gov)

    • The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued an order that identifies the virtual currency exchange Bitzlato Limited (“Bitzlato”) as a “primary money laundering concern” in connection with Russian illicit finance
    • The order prohibits certain transmittals of funds involving Bitzlato by any covered financial institution
    • For the order document issued by FinCEN see below: https://www.fincen.gov/sites/default/files/shared/Order_Bitzlato_FINAL%20508.pdf


Remaining Deadlines for Q1 2023:

  • 31 March, 2023: BMA Fees (for IFA/IBA/Mutual Fund Administrators)
  • 31 March, 2023: Government Fees and Annual Declarations/Returns (ROC) – Local Companies   

Deadlines for Q2 2023:

  • 30 April, 2023: Certificate of Compliance BMA
  • 30 April, 2023: Filing of Audited Accounts - BSX


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