Deterring money laundering and the financing of terrorism is about creating value as well as compliance. KPMG can assist you in meeting your Bermuda Anti-Money Laundering and Anti-Terrorist Financing obligations.
Bermuda as a jurisdiction will be subject to a Mutual Evaluation by the regional body of the FATF in 2018, and a positive outcome will be crucial for retaining and attracting business and investment to Bermuda.
The Bermuda Monetary Authority (“BMA”), remains committed to maintaining the international integrity of the jurisdiction. To this end, it has continued to strengthen the AML/ATF regulatory environment in Bermuda and introduced updated Proceeds of Crime (Anti-Money Laundering (“AML”) and Anti- Terrorist Financing (“ATF”)) Regulations 2008, effective January 1, 2016, as well as accompanying guidance notes, and issued draft sector specific guidance notes for consultation.
AML/ATF regulated financial institutions:
Designated non-financial businesses and professionals, including:
All entities in scope of the regulations must adopt a "risk based approach" to the detection and prevention of money laundering and terrorism financing measures and have in place the following:
Many financial institutions are experiencing difficulties keeping up with the ever increasing requirements of the regulations. Particular challenges which clients may face include:
AML/ATF Independent Audits
The requirement for an annual, independent audit of AML/ATF compliance provides an opportunity for an entity to regularly review its overall AML/ATF framework, and respond to changes in regulations in a cost effective and efficient manner. We have a team experienced in performing AML/ATF audits using KPMG’s global AML/ATF methodology.
KPMG’s global methodology outlined below focuses on the twelve key areas, of your AML & ATF program, allowing us to gain an understanding of the elements of your AML & ATF compliance program and how these elements interface to effectively meet your AML & ATF regulatory requirements. Our assessment will identify opportunities to enhance your AML & ATF program, in addition to testing compliance. Our deliverable will be an easy to read report using red, amber, green rating of the components of your framework.
AML/ATF Framework Assistance
Our Bermuda based professionals work with businesses to assess compliance gaps, help design, build and maintain robust AML/ATF programs, policies, procedures, systems and controls. We help clients fulfil their compliance obligations in an effective, timely and cost-effective manner that reduces business disruption and is proportional to the level of risk actually faced. Importantly, we help clients go beyond mere compliance to extract tangible value from their AML/ATF operations.
Developing and undertaking due diligence programs
We can assist with the daily implementation of due diligence programs and the provision of staff to address experience and resource constraints.
We can assist clients remediate their client files either proactively or in response to on-site findings by the BMA. Our large team of AML/ATF specialists allows us to quickly respond to your need for additional resources with extensive remediation expertise.
Additionally, in Bermuda we have recently been helping clients by:
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