The amendments insert two definitions into regulation 2:

• "CPF" is defined as counter-proliferation financing.
• "Proliferation financing" captures the provision of funds or financial services used, in whole or in part, in the manufacture, acquisition, development, export, trans-shipment, brokering, transport, transfer or stockpiling of, or otherwise in connection with the possession or use of, chemical, biological, radiological or nuclear (CBRN) weapons. The definition extends to the means of delivery of such weapons and to other CBRN-related goods and technology for non-legitimate purposes in contravention of international sanctions obligations in operation in Bermuda.

The sanctions nexus is significant: PF is framed not as a free-standing predicate but by reference to Bermuda's existing international sanctions obligations.

Rather than create a parallel regime, the amendments thread PF and CPF through the existing obligations, so the operative requirements are largely unchanged in mechanism but broadened in scope:

• Risk assessment and controls now expressly extend to proliferation financing, with "or terrorist financing" replaced by ", terrorist financing or proliferation financing" across the customer, business and risk-assessment provisions (regulations 6, 8, 10, 16, 17 and 18, and the Schedule).
• The "AML/ATF" shorthand becomes "AML/ATF/CPF" in the policies, procedures and controls provisions (regulations 12, 14A and 17A), so internal frameworks, documentation and governance references will need to be updated to reflect the third limb.
• Counter-proliferation financing control is added as a distinct control category alongside AML and ATF controls (regulations 11(3)(c), 12A(c) and 18(2)(b)).

Two changes tie the regime more closely to sanctions compliance:

• Regulation 9(1)(d) now also refers to the International Sanctions Act 2003 and any regulations made under it, extending the relevant statutory basis beyond the Anti-Terrorism (Financial and Other Measures) Act 2004.
• Regulation 11(3B)(c) is expanded so that internal reporting captures "breaches of international sanctions obligations" in addition to AML/ATF offences.

• Regulated persons should revisit business and customer risk assessments to ensure PF is identified and assessed as a discrete risk, not subsumed within terrorist financing.
• AML/ATF policies, procedures and training materials should be re-papered to the AML/ATF/CPF standard, including a dedicated CPF control framework.
• Internal reporting and escalation channels should be reviewed so that suspected sanctions breaches are routed alongside AML/ATF concerns.

The amendments align Bermuda more closely with FATF expectations on proliferation financing, but the practical burden lies in operationalising the new CPF limb across existing systems rather than in any wholesale change to the compliance architecture.

Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Amendment Regulations 2026 can be accessed here.

The Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008 can be found here.