Effectiveness Review Presenter: Shauna MacKenzie Director, Legal Services & Enforcement Bermuda Monetary Authority

2 Institution’s Due Diligence Customer Due Diligence  Annual Independent audit Compliance Officers  Qualifications/fitness and propriety  Notify the BMA of changes

3 Operations of Regulator  More AML examinations  Onsites - more identification of risks  - Offsites with profile and statistics  Domestic Cooperation and Communications – FIA/ BPS

4 Training 1.More SAR’s – more attention to high networth investors 2.CDD Quality of copies - consistent list of documents for records ID verification – need to procure documents to verify wealth Guidance for ultimate beneficial owner Greater sensitivity to layering practices Clear updating on PEP’s Equivalent Countries

5 3.Smaller entities – ongoing monitoring of transactions How to apply risk based in P & P’s 0 need to delve more into international risk assessment work on other countries – ICRG

6 Any queries?