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Bermuda

Scope of the Travel Rule

“Any Regulated Financial Institution (RFI) including an RFI conducting Digital Asset Business (DAB), that provides services for the transfer of digital assets (virtual assets), money transmission, or other transfer of funds, is a payment service provider (PSP) engaging in a wire transfer and is subject to the rules for wire transfers set forth in POCR Regulations 21 through 31A and Chapter 8: Wire Transfers”. 

Supervisory body

Bermuda Monetary Authority

Threshold

USD 1000

In order to comply with the FATF’s Travel Rule and meet AML requirements, the following information is to be exchanged:

  • Originator's name,

  • Originator's account number, 

  • Originator's address or national identity number, customer identification number or date and place of birth,

  • Beneficiary’s name, 

  • Beneficiary’s account number.

When do you need to comply?

Legislation in accordance with the Financial Action Task Force’s (FATF’s) Travel Rule is being drafted. To be activated within 2022. 

Applicable regulation

2021 Guidance Notes for AML/ATF Regulated Financial Institutions on Anti-Money Laundering and Anti-Terrorist Financing, Annex VIII, Sector-Specific Guidance Notes (SSGN) for Digital Asset Business

Proceed of Crime Act

The Digital Asset Business Act 2018

What else do you need to know

Any person carrying out any of the following activities has to be licensed:

  • Redeeming, issuing, or selling any form of digital assets. This includes, but is not limited to virtual coins and tokens, 

  • Operating as a payment service provider business utilizing digital assets, including the provision of services for the transfer of funds,

  • Operating as an electronic exchange,

  • Providing custodial wallet services,

  • Operating as a digital assets services vendor.

Written by:
Delphine Forma
Delphine Forma
Senior Compliance Manager at BitMEX

Delphine Forma is an experienced compliance officer who worked across different industries including Bank of Tokyo, Mitsubishi UFJ, HSBC Bank, and crypto businesses (exchanges and miners). She holds a diploma from Sciences Po Lyon, and two masters specialising in European Criminal Business Law and Frauds and Money Laundering Prevention. Delphine is a board member of the OpenVASP Association.

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