These changes aim to align Bermuda’s anti-money laundering, anti-terrorist financing and combat proliferation financing (AML/ATF/CPF) framework with updated Financial Action Task Force (FATF) standards ahead of NAMLC’s 5th Round of Mutual Evaluation in October 2026.

• Proliferation financing risk assessment: Introducing legislative requirements for identifying, assessing and mitigating proliferation financing risks.
• NAMLC membership: Adding the Permanent Secretary of the Ministry of National Security as a statutory member.
• Enforcement authority: Designating the Attorney-General’s Chambers as the enforcement authority for civil recovery matters.
• Transparency in registration cancellations: Requiring publication of cancellation notices for non-licensed AML/ATF regulated financial institutions or regulated non-financial businesses or professions.
• Civil penalties: Expanding the scope of civil penalties for breaches of AML/ATF regulations.
• Legislative updates: Addressing outdated references and resolving conflicting provisions.
• Supervisory authority powers: Enhancing powers to issue rules, codes of conduct and statements of principle.
• Correspondent relationships: Broadening the definition to include all financial institutions, not just banks.
• Trustee reporting obligations: Extending suspicious activity reporting requirements to non-professional trustees.

NAMLC invites stakeholders to review the consultation paper and submit feedback by 30 July 2025. The Consultation paper can be found here.