ARTICLE
19 October 2026

Podcast: AML Requirements For DABA Applications

A
Appleby

Contributor

Appleby is one of the world’s leading offshore law firms, operating in 10 highly regarded and well-regulated locations. We provide comprehensive, expert advice and services across a number of key practice areas. We work with our clients to achieve practical solutions whether from a single location or across multiple jurisdictions.
George McCallum, Karim Creary, and Jarion Richardson examine Bermuda's anti-money laundering framework for Digital Asset Business Act licence applications, exploring the policies, procedures, and governance structures that applicants must establish. The discussion reveals common pitfalls in AML programme preparation and explains how the Bermuda Monetary Authority evaluates compliance effectiveness.
Bermuda Finance and Banking

Listening Time: 32 Minutes

Episode Background

Bermuda Shorts – Tech Talks S01 E24

In this episode of #TechTalks, the spotlight turns to one of the most important aspects of any Digital Asset Business Act (DABA) licence application: anti-money laundering compliance. George McCallum and Karim Creary, lawyers in Appleby’s #Bermuda Technology practice who specialise in advising on DABA licensing matters, are joined by Jarion Richardson, Appleby’s Regulatory, Governance & Compliance Advisory Lead and a highly experienced AML specialist, to offer an insightful look at Bermuda’s AML framework and the regulatory expectations facing prospective applicants.

The discussion explores the policies, procedures and governance frameworks applicants are expected to establish, as well as how the Bermuda Monetary Authority (BMA) assesses the strength and effectiveness of an AML programme. The trio also consider the key personnel and reporting obligations involved, alongside important requirements relating to customer due diligence, ongoing monitoring and outsourcing arrangements.

Drawing on Jarion’s specialist regulatory compliance experience, the conversation provides practical insight into common pitfalls and misconceptions that can arise when preparing an AML programme. Together, George, Karim and Jarion offer prospective applicants a valuable overview of what to expect during the regulatory assessment process and why a robust, carefully considered AML framework is essential from the outset.

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

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