Bermuda
Overview
Bermuda’s Deep AML/CFT profile is anchored in Proceeds of Crime framework and the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008. The profile separates the primary legal baseline from later regulations, sector guidance, CFATF mutual-evaluation evidence and current FATF monitoring status so that historical assessment findings are not presented as current law.
Beneficial-ownership duties are mapped through Bermuda’s CDD/legal-person framework and the CFATF fourth-round effectiveness/technical-compliance layer. The profile separates the legal requirement to identify and verify beneficial owners from the availability, quality and timeliness of registry or other competent-authority access.
Reporting entities are mapped to risk-based CDD, ongoing monitoring, record-keeping and suspicious-transaction reporting to Financial Intelligence Agency Bermuda. Sector-specific thresholds, supervisors and filing mechanics remain subordinate to the national statutory framework and are not generalized beyond the mapped official evidence. In June 2026 the Barristers and Accountants AML/ATF Board issued Version 2 guidance for legal and accounting firms covering risk-based controls, CDD/EDD, monitoring, SAR and sanctions reporting, CPF and internal governance.
Compliance Calendar2
Requirement
Suspicious activity report
Authority / Report toBermuda Financial Intelligence Agency (FIA)
Deadline / triggerSubmit promptly in accordance with the applicable Proceeds of Crime / AML/ATF rule; no universal numeric outer limit is asserted here.
Requirement
- Subject scope
- Persons/entities subject to Bermuda AML/ATF reporting obligations.
- Trigger
- Knowledge, suspicion or reasonable grounds meet the applicable reporting threshold.
- Filing channel
- goAML reporting platform / FIA prescribed process.
Impact
- Consequences of non-compliance
- Failure to report may attract criminal, regulatory or supervisory consequences.
- Enforcement authority
- FIA / BMA / competent supervisor
- Operational impact
- Escalate immediately to the reporting officer, file through goAML as required, and retain the submission/analysis trail.
Requirement
AML/ATF risk controls and supervisory compliance
Authority / Report toBermuda Monetary Authority / competent supervisor
Deadline / triggerMaintain risk assessment, CDD/beneficial-owner controls, monitoring, reporting governance, training and records under applicable rules.
Requirement
- Subject scope
- BMA-regulated and other reporting entities within Bermuda’s AML/ATF perimeter.
- Trigger
- Continuous while conducting covered business and as risk changes.
- Filing channel
- Internal compliance programme and retained evidence.
- Legal basis
- Bermuda Financial Intelligence Agency · Official siteFIA officialBermuda Monetary Authority · Supervision & RegulationSupervisor officialBMA / FIA · ML/TF/PF Reporting Indicators (2025)Official guidanceUpdated AML/ATF/CPF & Sanctions Guidance Notes for the Legal and Accounting SectorsOfficial sector guidance
Impact
- Consequences of non-compliance
- Deficiencies may attract BMA or other statutory sanctions.
- Enforcement authority
- BMA / competent supervisor
- Operational impact
- Maintain a sector control matrix. Legal and accounting firms supervised by the Barristers and Accountants AML/ATF Board should align risk assessment, CDD/EDD, monitoring, SAR/sanctions, CPF, outsourcing, training, records and internal-audit controls with Version 2 guidance.
Authorities & FIU1
FATF Assessment
Measures how fully the jurisdiction has implemented FATF’s technical requirements. It does not measure practical effectiveness.
Measures whether the AML/CFT system achieves its intended results in practice. Follow-up reports do not normally replace these ratings.
Explore 40 FATF RecommendationsSee every Technical Compliance rating and what it means.+
Explore 11 Immediate OutcomesSee how FATF rates whether the AML/CFT system works in practice.+
Regulatory Timeline42
The Revenue (Customs Traveller Declaration) Amendment Notice 2026 was published on 30 September and came into operation on 1 October 2026. Departing travellers must declare precious metals and precious stones with a cumulative value above BDA 10,000.
Bermuda’s Official Gazette published the Beneficial Ownership Regulations 2026 and Beneficial Ownership Exemption Order 2026 on 25 September 2026, implementing the amended beneficial-ownership framework.
Bermuda’s Official Gazette published the Proceeds of Crime (Miscellaneous) Act 2026 Commencement Day Notice 2026 on 25 September 2026.
Bermuda enacted the Beneficial Ownership Amendment Act 2026 as part of its September legislative package to further align beneficial-ownership transparency with revised FATF standards.
Bermuda’s September 2026 legislative package includes the Charities Amendment (No. 2) Act 2026 and Charities Amendment Regulations 2026, updating the charities framework in connection with the revised FATF Recommendation 8 approach.
Bermuda’s September 2026 legislative package includes the Financial Intelligence Agency Amendment Act 2026, updating the statutory framework for the Financial Intelligence Agency.
Bermuda’s September 2026 legislative package includes the Proceeds of Crime Amendment Act 2026, an asset-recovery reform to the Proceeds of Crime Act 1997.
Bermuda’s Barristers and Accountants AML/ATF Board published Version 2 AML/ATF/CPF and sanctions guidance for legal and accounting sector firms, reflecting the 2024 National Risk Assessment and expanding practical guidance on risk-based controls, CDD/EDD, monitoring, reporting, CPF, sanctions and internal governance.
FATF revised Recommendation 16 to standardise payment information and strengthen fraud/error controls in cross-border payments.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendation 1 and related interpretive material to strengthen proportionality and simplified measures under the risk-based approach.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF revised Recommendations 4, 30, 31 and 38 and related interpretive material to make asset recovery a stronger operational priority, expand tools to trace and confiscate criminal property and improve domestic and international cooperation.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗At its February 2023 Plenary FATF revised Recommendation 25 and its Interpretive Note to strengthen transparency and beneficial-ownership requirements for trusts and similar legal arrangements, complementing the 2022 strengthening of Recommendation 24 for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF strengthened Recommendation 24 on beneficial ownership transparency for legal persons.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗FATF amended Recommendations 1 and 2 and their Interpretive Notes so countries and covered private-sector entities must identify, assess and mitigate risks of breaches, non-implementation or evasion of proliferation-related targeted financial sanctions.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee revised its ML/TF risk-management guidelines to add principles for information exchange and cooperation between prudential and AML/CFT supervisors in authorisation, ongoing supervision and enforcement.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted detailed implementation requirements for virtual assets and VASPs in June 2019, including the application of wire-transfer information requirements commonly described as the Travel Rule. This operationalised the virtual-asset perimeter introduced through the 2018 Recommendation 15 revision.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗In October 2018 FATF revised Recommendation 15 and added the definitions of virtual asset and virtual asset service provider, formally bringing virtual-asset activity into the global AML/CFT standards architecture. Detailed implementation requirements followed in 2019.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee issued Sound management of risks related to money laundering and financing of terrorism, superseding its 2001 CDD and 2004 consolidated KYC papers and integrating ML/TF risk management with prudential supervisory expectations.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF adopted a consolidated revised set of 40 Recommendations integrating AML, CFT and proliferation-financing safeguards.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Bermuda brought the 2008 AML/ATF Regulations into force, replacing the earlier rules and embedding risk-based preventive obligations.
Resolution 1737 imposed binding measures concerning Iran’s proliferation-sensitive nuclear activities, including an asset freeze on designated individuals and entities. Together with the DPRK regime, it forms a foundational UN counter-proliferation targeted-financial-sanctions architecture.
No standalone Article 25 claim is made for this profile. The parent-State, constitutional and local implementation route must be verified separately.
UN Charter · Article 25 ↗Following the DPRK nuclear test, Resolution 1718 imposed binding sanctions including an asset freeze on designated persons and entities connected to the nuclear programme. It became a central UN targeted-financial-sanctions pillar for counter-proliferation financing.
No standalone Article 25 claim is made for this profile. The parent-State, constitutional and local implementation route must be verified separately.
UN Charter · Article 25 ↗FATF added a ninth Special Recommendation addressing cash couriers and cross-border movement of currency.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1540 requires all States to adopt and enforce laws and domestic controls to prevent non-State actors from acquiring or using weapons of mass destruction and related materials. It forms a binding global legal pillar of the proliferation-financing control environment later reflected in FATF CPF standards.
No standalone Article 25 claim is made for this profile. The parent-State, constitutional and local implementation route must be verified separately.
UN Charter · Article 25 ↗The UN General Assembly adopted the United Nations Convention against Corruption on 31 October 2003. UNCAC addresses prevention of money laundering, laundering of corruption proceeds, confiscation and a dedicated asset-recovery framework; the Convention entered into force globally on 14 December 2005.
The UN depositary records territorial application/extension of 2003 UN Convention against Corruption to this profile. This is not independent State-Party status and carries no implication about sovereignty; domestic implementation remains a LOCAL evidence question.
UN Treaty Collection ↗FATF comprehensively revised its AML/CFT Recommendations, strengthening preventive measures and extending coverage.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Basel Committee issued Customer due diligence for banks, setting minimum supervisory expectations for customer acceptance, identification, ongoing monitoring and risk management. It became an influential global banking KYC/CDD benchmark and was later reflected in FATF standards.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗FATF expanded its standards to terrorist financing through eight Special Recommendations.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Resolution 1373 requires all States to prevent and suppress terrorist financing, criminalise the provision or collection of funds for terrorist acts, freeze terrorist assets without delay and prohibit making funds or financial services available to terrorists and related entities.
No standalone Article 25 claim is made for this profile. The parent-State, constitutional and local implementation route must be verified separately.
UN Charter · Article 25 ↗The Palermo Convention was adopted on 15 November 2000 and broadened the international money-laundering framework beyond drug proceeds through criminalisation and preventive measures tied to transnational organised crime. It entered into force globally on 29 September 2003.
The UN depositary records territorial application/extension of 2000 Palermo Convention to this profile. This is not independent State-Party status and carries no implication about sovereignty; domestic implementation remains a LOCAL evidence question.
UN Treaty Collection ↗The UN General Assembly adopted the International Convention for the Suppression of the Financing of Terrorism on 9 December 1999, creating the treaty framework for criminalising terrorist financing and international cooperation. It entered into force globally on 10 April 2002.
The UN depositary records territorial application/extension of 1999 Terrorist Financing Convention to this profile. This is not independent State-Party status and carries no implication about sovereignty; domestic implementation remains a LOCAL evidence question.
UN Treaty Collection ↗Resolution 1267 imposed an assets freeze and other targeted sanctions in the Taliban context and created the Security Council committee that became the foundation of the UN 1267 sanctions architecture. It is a key global precursor to modern terrorist-financing targeted financial sanctions.
No standalone Article 25 claim is made for this profile. The parent-State, constitutional and local implementation route must be verified separately.
UN Charter · Article 25 ↗FinCEN-sourced historical membership data records Bermuda's FIU among Egmont admissions in 1999. The current Egmont roster carries a different raw admission value (2009-05-26), which is preserved separately rather than used to overwrite the historical relationship start.
Bermuda’s government AML framework identifies the Proceeds of Crime Act 1997 as the legislative foundation for money-laundering offences, proceeds recovery and later preventive regulations. The 2008 AML/ATF regulations build on this earlier statute.
Historical official-government evidence confirms Bermuda as a CFATF member by November 1996 following formalisation of the organisation through the 1996 MOU; the reviewed evidence does not establish the jurisdiction’s original admission date.
FATF revised the Forty Recommendations to reflect evolving money-laundering methods and countermeasures.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗Representatives of 13 financial intelligence units met in Brussels on 9 June 1995 and founded what became the Egmont Group. The milestone created the operational global network for FIU-to-FIU cooperation and exchange of financial intelligence.
Current profile relationship to the Egmont network. This does not imply membership in 1995; admission history is a separate LOCAL/STATUS fact.
Egmont Group · Member FIUs ↗A contemporaneous UN ECLAC report states that the 1992 Kingston Declaration was signed by 26 jurisdictions and expressly names the non-signatories; Bermuda is not among those exceptions. Read together with the Kingston Declaration's CFATF-member implementation framework, this fixes Bermuda's founding CFATF membership boundary in November 1992. The date is kept at month precision because the meeting ran 5–6 November and the evidence does not identify a jurisdiction-specific signature day.
FATF issued its original Forty Recommendations, establishing the first global AML standard framework.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The G7 established FATF in 1989 to examine and develop measures to combat money laundering. FATF became the central global standard-setting body whose recommendations are implemented through national and regional AML/CFT frameworks.
Current relationship. This is regional assessment network participation, not direct FATF membership. The GLOBAL standard remains separate from evidence of domestic implementation.
FATF Global Network ↗The Vienna Convention was adopted on 20 December 1988 and created the first treaty-level international obligation to criminalise laundering conduct linked to drug-trafficking proceeds, alongside confiscation and international-cooperation measures. It entered into force globally on 11 November 1990.
The UN depositary records territorial application/extension of 1988 Vienna Convention to this profile. This is not independent State-Party status and carries no implication about sovereignty; domestic implementation remains a LOCAL evidence question.
UN Treaty Collection ↗The Basel Committee published a Statement of Principles for banks aimed at reducing the risk that banking institutions would be used by criminals or as channels for money laundering. This helped establish the preventive and supervisory side of AML alongside the emerging criminal-law framework.
A Basel supervisory publication does not become domestic law merely because it is GLOBAL. National adoption, supervisory use or incorporation must be evidenced by a LOCAL milestone or source.
Basel Committee on Banking Supervision ↗