Bermuda regulatory update Q1 2025
Recent developments from the Bermuda Monetary Authority (“BMA”) and the Office of the Privacy Commissioner (“PrivCom”) reflect continued regulatory focus on financial sanctions, operational resilience, and data privacy. New consultations, guidance notes, and enforcement activity highlight the need for regulated entities to review internal processes, ensure appropriate due diligence, and meet upcoming Q2 2025 deadlines. The summary below outlines key changes and actions relevant to Bermuda-regulated entities.
BMA: Financial sanctions updates
• Financial sanctions have been published/updated by the BMA for: Libya; Counter-Terrorism; Venezuela; Russia; Belarus; Global Human Rights; and Global Anti-Corruption (see International Sanctions - BMA)
• AML-ATF Ministerial Advisory 1 2025 (dated March 13, 2025 – see AML/ATF - Policy and Guidance - BMA):
o Enhanced due diligence (“EDD”) must be applied for high risk jurisdictions, based on the Financial Action Task Force’s (“FATF’s”) list (see High-Risk Jurisdictions Subject to a Call for Action - February 21, 2025)
o A risk-based approach, which may include EDD, should be applied for jurisdictions that are under increased monitoring by the FATF, due to strategic deficiencies in their AML/CFT regimes (per the Jurisdictions under Increased Monitoring - February 21, 2025 statement)
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