Bermuda publishes its first proliferation financing risk assessment
Key findings
The assessment examined PF threats from DPRK, Iran, Russia and Syria, with DPRK, Iran and Russia rated as medium PF threats to Bermuda, while Syria is rated as low.
Sector-by-sector vulnerability assessments produced a differentiated risk picture:
- Digital asset businesses (DABs) received the highest vulnerability rating of any sector with a rating of high. The assessment drew a distinction between licence classes: Class M (Modified) and Class F (full) licences were rated high risk, reflecting the breadth of permitted services, cross-border transaction flows, and exposure to impersonation vulnerabilities, while Class T (testing) licences were rated medium owing to strict activity limits. No evidence of exploitation by PF actors was identified, but the sector's inherent characteristics were flagged as susceptible to misuse.
- Banking was rated medium Only four licenced banks operate in Bermuda, and no PF activity has been recorded in the sector; however, the assessment highlighted exposure through cross-border transfers and international correspondent relationships. Wealth management and private banking sub-sectors were rated medium, while credit unions were rated low.
- Securities were rated medium, driven by rapid cross-border transactions, multiple intermediaries, and complex corporate investor structures.
- Insurance (long-term), legal sector, trust and corporate service providers were each rated medium, with the trust sector’s rating reflecting its international client base and complex structuring capabilities.
- Counting, real estate, lending, and casino gaming were all rated low.
- Legal persons and legal arrangements were assessed with a medium inherent vulnerability.
Across all sectors, no instances of PF activity were identified during the assessment period, and no direct sectoral ties to DPRK, Iran, or Syria were found.
Next steps
The PF NRA is designed to inform Bermuda's National PF Action Plan and feed into ongoing risk-based supervision. The Government has committed to periodic updates to reflect evolving risks and to maintain the integrity of Bermuda's financial system.
Regulated entities should expect the findings to shape supervisory expectations, particularly in the digital asset and banking sectors, where inherent vulnerability ratings are highest.
The Report can be found here.
