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Overview
The Bermuda Monetary Authority (BMA) announced that, effective 1 October 2026, applications involving AML/ATF regulated financial institutions must include a Police Clearance Certificate (PCC) for each Key Person undergoing vetting along with their personal declaration form. A "Key Person" is anyone subject to a fit and proper assessment under the relevant Regulatory Acts' licensing or registration criteria.
Scope of New Policy
This new requirement applies not only to new applications submitted to the BMA but also extends to any subsequent changes involving a Key Person within an AML/ATF regulated financial institution. This means that if there is a change in personnel—such as the appointment of a new Key Person or the replacement of an existing one—a Police Clearance Certificate must be provided for every relevant individual involved in the change.
- The specific requirements of PCCs are as follows:
- The PCC must be issued within the past 12 months when submitted.
- Applicants must provide a PCC from each country where they lived as an ordinary resident for over six months in the last three years.
- If a PCC is unavailable, the BMA may accept suitable alternative documents on a case-by-case basis.
Purpose and Impact
The introduction of this policy aims to further strengthen the fit and proper vetting process for individuals who hold significant roles within AML/ATF regulated financial institutions. This measure is expected to improve the overall reliability and security of Bermuda’s financial sector and its compliance with international standards on anti-money laundering and countering terrorist financing.
Conclusion
In summary, starting October 1, 2026, stakeholders must be prepared to submit Police Clearance Certificates for all Key Persons as part of the application process or when making changes to personnel within AML/ATF regulated financial institutions. This policy underscores the BMA’s commitment to maintaining high regulatory standards and safeguarding the interests of the financial sector.
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