Bermuda's ML/TF risk landscape: Key takeaways from the 2024 NRA assessment
02 Jan 2026
|
The Government of Bermuda, through the National Anti-Money Laundering Committee (NAMLC), released its 2024 National Risk Assessment (NRA), marking the fourth such assessment. This comprehensive report evaluates Bermuda's exposure to Money Laundering (ML) and Terrorist Financing (TF) risks, providing insights to strengthen national policies and private sector resilience.
Key findings:
Money Laundering (ML) risks:
- High-risk areas: Drug trafficking, foreign-sourced fraud, foreign-sourced market manipulation / insider training and foreign-sourced corruption/bribery remain the primary proceeds generated ML threats.
- Sectoral risks: The deposit-taking, securities, trust business, corporate service provider and legal sectors are rated as having high inherent ML risks due to their international exposure and transaction volumes.
- Emerging risks: The Economic Investment Residential Certificate (EIRC) program, introduced in 2023, was assessed for the first time, receiving a medium ML high risk rating due to its potential exposure to high-value investments.
Terrorist Financing (TF) risks:
- Bermuda's TF threat remains low, with no evidence of domestic or cross-border TF activities. The nonprofit sector, while assessed for TF vulnerabilities, showed no significant risks.
Sectoral insights:
- Digital Asset Businesses (DABs): Rated medium-high for ML risk due to the global nature of digital assets and potential misuse for illicit activities.
- Real Estate: Medium ML risk, influenced by foreign investments, including through the EIRC program.
- Nonprofit Organisations (NPOs): Low TF risk, with robust oversight and no evidence of misuse.
Global cooperation:
- Bermuda continues to collaborate with international bodies to address ML/TF risks, aligning with Financial Action Task Force (FATF) standards.
The findings will guide updates to Bermuda's AML/ATF policies, ensuring the jurisdiction remains resilient against evolving financial crimes.
For more information, the Report can be found here and the press release here



