Bermuda’s National Anti-Money Laundering Committee (NAMLC) published a consultation paper proposing amendments to the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008 to introduce explicit proliferation financing (PF) risk assessment and risk mitigation obligations for AML/ATF regulated entities. The package is intended to align Bermuda’s framework with recent Financial Action Task Force (FATF) revisions to Recommendation 1, where PF risk is defined as the potential breach, non-implementation or evasion of targeted financial sanctions obligations under Recommendation 7. The consultation follows Bermuda’s 2025 PF National Risk Assessment, which found PF risk evaluation and mitigation measures for regulated entities were absent from the legislative framework. Proposed changes include new definitions of PF and counter-proliferation financing (CPF), requirements for regulated entities to identify, document, and keep PF risk assessments up to date and provide information to competent authorities and self-regulated bodies, and senior-management-approved policies, controls and procedures to manage and mitigate PF risk on a proportionate basis. The annexed draft amendments also integrate PF/CPF into customer due diligence, simplified and enhanced due diligence, correspondent banking expectations, group-wide controls for branches and subsidiaries (including notification to the Bermuda Monetary Authority where host-country laws prevent equivalent measures), outsourcing requirements, systems and controls, internal reporting, and staff training, with scope covering regulated financial institutions (including digital asset businesses), independent professionals, casino operators, dealers in high value goods, and real estate brokers and professions. Written comments are requested by February 11, 2026.
Bermuda Monetary Authority 2026-01-28
Bermuda’s National Anti-Money Laundering Committee launches consultation on embedding proliferation financing risk assessments and controls in AML and ATF regulations
Bermuda’s National Anti-Money Laundering Committee has issued a consultation on amendments to the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008 to introduce explicit proliferation financing risk assessment and mitigation obligations for regulated entities, aligning with revised FATF Recommendation 1. The draft amendments define proliferation and counter-proliferation financing and embed related requirements into customer due diligence, correspondent banking, group-wide controls, outsourcing, systems and controls, internal reporting, and staff training across all regulated sectors, including digital asset businesses.