What does money laundering have to do with Bermuda?
The worldwide campaign against money laundering affects us all. Bermuda’s future as a financial centre depends on ensuring a robust anti-money laundering regime grounded in tough regulations, rigorous supervision and effective enforcement is in place to combat threats. The fact is, no single nation has the power to end money laundering; if one country is hostile to laundering, criminals move to another territory. Unchecked, money laundering and terrorism financing have the potential to cause devastating damage—for individual businesses, national economies, and beyond. Global cooperation and collaboration are essential. Bermuda needs to continue its leadership role in the global network to protect our reputation as a top-tier financial centre.
What do AML and ATF mean?
AML stands for "anti-money laundering" while ATF is "anti-terrorist financing." They refer to laws, policies and procedures in each country detecting and preventing financial crime and concealment of its proceeds. Each nation's framework governing AML and ATF is aligned with international regulatory standards. For example, financial institutions such as banks are required to comply with protocols to help prevent illegal use of their services.
What does KYC mean?
KYC stands for "Know Your Customer." It refers to standard practices used by financial institutions like banks to obtain information about their customers to prevent their services being misused. This helps banks and other entities identify suspicious activity. The information needed can include identification of names and addresses, and source of funds.
How is Bermuda working on AML-ATF issues with the rest of the world?
Bermuda has an important role to play as an international financial centre in protecting the integrity of the world's financial markets. A Bermuda government Cabinet committee is monitoring progress leading up to an external assessment by the Caribbean Financial Action Task Force (CFATF) taking place later this year. Our National Anti-Money Laundering Committee (NAMLC) is working to strengthen Bermuda's anti-money laundering and counter-terrorist financing framework, and industry is also working hard on the front lines, as this is critical to our economy.
Why is there a public awareness campaign?
Just Good Business campaign aims to educate Bermuda residents about the importance of complying with Bermuda's AML and ATF laws and regulations. The message is that money laundering and terrorist financing affect everyone, directly or indirectly, from individuals to financial and non-financial businesses. It will also encourage greater appreciation for those tasked with implementing protocols—folks like compliance officers and frontline employees at financial institutions. The effort demonstrates how serious Bermuda and its citizens are about tackling threats of money laundering and terrorism financing.
What is meant by "compliance" work?
Compliance officers are the professionals in our banks, law firms, re/insurance companies, retail businesses—even our non-profit organisations—responsible for ensuring their organisations comply with rules and regulations to prevent money laundering and terrorist financing in Bermuda. Policies and procedures at each organisation are designed to provide a framework for prevention and detection. Compliance officers ensure the framework is set up and adhered to; they are the front line. However, they are not alone: many more of us have a duty to remain watchful. In a sense, we all have a compliance role.
Who's organising the campaign?
Bermuda's public awareness campaign is led by the National Anti-Money Laundering Committee (NAMLC). As the organisation responsible for coordinating Bermuda's programme to prevent money laundering and terrorist financing, NAMLC has a big mandate, but it is supported in this campaign by numerous stakeholder groups. These include: the Association of Bermuda International Companies (ABIC), the Association of Bermuda Insurers & Reinsurers (ABIR), the Bermuda Banking Association (BBA), the Bermuda Business Development Agency (BDA), Bermuda International Long Term Insurers & Reinsurers (BILTIR), Bermuda Insurance Management Association (BIMA), and the Bermuda Monetary Authority (BMA). The joint effort demonstrates Bermuda's commitment to combat financial crime.
Do people and businesses have to participate?
Yes, you have a legal obligation to report any suspicious activity you may encounter while operating a trade, business, or profession, or while in employment of any kind. Help safeguard Bermuda's reputation by being vigilant. We also ask that everyone fulfils their own obligations to complete and submit documentation that financial entities such as local banks may require to satisfy current international standards.
How do you recognise suspicious activity?
Here are some signs:
- If you work in a money service business (MSB) and a customer makes regular transactions by cash to different recipients
- If you work in a MSB and your customer doesn’t know the recipient or purpose of their transaction
- If you work in the financial industry and a clients only want to see a particular “friendly” teller/employee
- If you work in the financial industry and your employee conducts transactions through their own account for third persons
- If you work in a financial institution and see people with no known legitimate income open new accounts
- If you work in a financial institution and see a customer make regular deposits (either by ATM or through a teller) and then make immediate overseas transfers or purchases
- If you work in property/car insurance and a customer cancels insurance and seeks a cheque as reimbursement after paying in cash
- If you work in the travel industry and a client pays for high-price tickets last minute and in cash
- If cash payment is only mentioned by the customer at the conclusion of the transaction
- If the instruction on the form of payment changes suddenly just before the transaction goes through
- If, in the case of refunds, a customer:
- inquires about the business’ refund policy before making the purchase
- seeks a refund for spurious reasons
- seeks repayment in the form of a cheque
Who do I contact if I suspect something?
You can report suspicious activity confidentially to the Financial Intelligence Agency (FIA).
To make a report as an individual, click here.
To make a report as an organisation, click here.
To make a report as an FIA-registered user, click here.
What is the 2018 CFATF Mutual Evaluation of Bermuda?
The CFATF Mutual Evaluation takes place in 2018, but the final report will not be completed until 2019. A team of professionals from various countries will review Bermuda's AML–ATF laws, policies and procedures and assess their effectiveness. Over the first half of 2018, Bermuda must submit a completed questionnaire and self-assessment to CFATF assessors. After reviewing the submission, they will visit the island in the second half of 2018 to meet with authorities, financial and non-financial businesses, and assess whether processes and protocols are being met and global obligations fulfilled.
Is the CFATF's 2018 assessment important to Bermuda?
It is critical to Bermuda's reputation as a global finance centre and, by extension, to our economy. A positive assessment tells the international business community our jurisdiction is tough on money laundering and terrorist financing and meets global standards. As a result, the Bermuda government has made preparation for the assessment a national priority.
How is Bermuda perceived as an international financial centre?
Bermuda is respected as a sophisticated, top-tier global finance centre with a robust regulatory framework that meets international standards. Our jurisdiction has also demonstrated leadership on compliance, tax-transparency and cooperation with countries around the world. The island has enjoyed an excellent reputation for many decades, and we want to retain that record.