Bermuda’s financial regulator is set to require police clearance certificates for key persons at regulated financial institutions from autumn.
From 1 October 2026, the new requirement will apply to applications involving AML/ATF regulated financial institutions where a key person must be vetted. It will also apply to changes to a key person at an AML/ATF regulated financial institution.
In a notice, the Bermuda Monetary Authority (BMA) said a key person includes anyone subject to the fit and proper assessment required by the minimum criteria for licensing or registration under Bermuda’s regulatory acts.
The requirement will be relevant to a range of regulated sectors including corporate service providers, trust businesses, investment businesses, fund administration firms and investment funds.
From 1 October, any person being vetted by the BMA as a key person for an AML/ATF regulated financial institution must submit a police clearance certificate with their personal declaration form. The certificate must be no more than 12 months old at the time of submission.
Applicants will also need to provide a certificate from each country where they have been ordinarily resident for more than six months at any time during the previous three-year period.
Where a certificate cannot be obtained from a relevant jurisdiction, the BMA said it may consider appropriate substitute documentation on a case-by-case basis.
The regulator said stakeholders should ensure that applications or notifications of changes to a key person submitted on or after 1 October include the required certificate documentation where applicable, but applications received in full before that date will not be subject to the requirement.
The BMA said it has a statutory responsibility to ensure that people who hold significant or controlling interests, or who perform senior management or other key functions in AML/ATF regulated financial institutions, are fit and proper.
“The requirement is intended to enhance the Authority’s ability to verify the fitness and propriety of Key Persons and to align Bermuda’s framework with international standards and regulatory practices in comparable jurisdictions,” it added.
The BMA said it will update relevant application guidance and forms to reflect the change. It also encouraged stakeholders to prepare early to avoid delays in the application process.
