Oyster Consultant Offers Legal Education Lecture
Oyster Consulting [Bermuda] Ltd Consultant Henry M. Komansky presented his second CLE lecture to the Bermuda Bar Association on April 6 to discuss changes to Bermuda’s Anti-Money Laundering/Anti-Terrorist Financing requirements.
A spokesperson said, “On 1 January 2016, the long-pending Bermuda Proceeds of Crime Amendment Act 2015 became law. There have been changes made to Bermuda’s Anti Money Laundering/Anti-Terrorist Financing [“AML/ATF”] requirements in a number of areas including: Client Due Diligence [“CDD”], outsourcing of AML/ATF functions, and the consent provisions related to the filing of Suspicious Activity Reports [“SARs”].
“The Act also created a new category of Domestic PEP [“DPEP”] and now mandates that a separate AML/ATF audit be conducted.”
“This new requirement for an AML/ATF audit brings Bermuda in line with FATF Recommendation 18 [and its interpretive notes]. The audit requirements are not necessarily onerous but they will be new to most AML/ATF regulated entities in Bermuda.
“It is important to realise that the audit requirement applies to all AML/ATF regulated entities, including all those supervised by the BMA under the AML/ATF Regulations as well as Regulated Professional Firms.
“I am looking forward to rolling out our audit program which leverages Oyster’s long experience conducting AML Audits for SEC-registered broker-dealers.”
