As you are all aware, the Barristers & Accountants AML/ATF Board Annual Registration for 2023 will officially open on October 1st, 2022 and will close on October 31st 2022.
In advance of this please find linked the “AML_ATF Information Bulletin 2023” and a “AML_ATF Registration FAQs” both containing relevant information which you can share within your organization. The “On -Line Registration Guidance 2023” with detailed instructions on the portal will follow in due course.
In addition, please see the following list of minor registration changes, all of which are designed to further streamline the registration process.
- Fit and Proper Persons (FPPs)
FFPs issued by the Bermuda Bar Association (BBA) and the Chartered Professional Accountants of Bermuda (CPA) no longer need to be uploaded to the portal unless specifically requested. This information will be provided to the AML/ATF Board by BBA and CPA respectively.
This does NOT apply to persons who are NOT members of those organizations.
All other FPPs must be submitted via the portal or by email.
The AML/ATF can provide FPP vetting and certificates for those persons in your organizations who need them through application with the AML/ATF Board office. The cost is $100 per FPP payable on receipt.
Regulated Professional Firms
- Mitigants Questionnaire (MQ)
The MQ is NOT required IF there is NO change in information from the previously submitted MQ for the 2022 registration period. Please review carefully before choosing not to submit.
The MQ is still required if:
a. A Regulated Professional Firms is registering with the Board for the first time.
b. If requested by the AML/ATF Board.
- Adequacy of Preventative Measures (NEW)
This is a new section which has been inserted between the “Risk Data Call” and the “Declaration” sections of the portal. It consists of 5 Yes/No questions and 4 text fields for explanations for your answers. Note that the fields cannot be blank….
The questions relate to:
a. Client Due Diligence/Screening/Onboarding
b. Enhanced Due Diligence
c. Record Keeping
d. Reporting and Monitoring