Bermuda’s 2026 Advisory on Money Laundering and Terrorist Financing Risks
03 Apr 2026
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On 24 February 2026, the Bermuda Ministry of Justice issued AML-ATF Ministerial Advisory 1/2026, emphasising the need for enhanced due diligence (EDD) and enhanced ongoing monitoring on a risk-sensitive basis in business relationships involving jurisdictions identified as high-risk for money laundering and terrorist financing. This advisory aligns with the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008, which mandate risk-sensitive EDD measures for transactions linked to such jurisdictions.
Key points include:
- High-risk jurisdictions: The Financial Action Task Force (FATF) has identified countries with strategic deficiencies in their AML/CFT frameworks. These include the Democratic People's Republic of Korea (DPRK), Iran, and Myanmar, among others. Specific countermeasures and EDD are advised for these jurisdictions.
- FATF statements: On 13 February 2026, FATF released statements categorising jurisdictions into:
- High-risk jurisdictions (Black list): Countries requiring countermeasures, such as DPRK and Iran.
- Jurisdictions under increased monitoring (Grey list): Countries working to address deficiencies, including Algeria, Kenya, and Vietnam.
- Regulatory compliance: Entities and persons subject to Bermuda’s AML/CFT regulations, including financial institutions, independent professionals, and real estate agents, must implement robust systems to mitigate risks associated with these jurisdictions.
- Sanctions and monitoring: Some jurisdictions, like DPRK and Iran, are subject to international sanctions, necessitating additional compliance measures under the International Sanctions Regulations 2013.
The advisory highlights the importance of consulting FATF publications and annexed statements for comprehensive risk assessments. It replaces previous advisories and reinforces Bermuda’s commitment to combating financial crime in alignment with international standards.
Bermuda’s AML-ATF Advisory 1/2026 can be accessed here



