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Breakdown of the Bermuda's Travel Rule Regulations

What is the scope of the Travel Rule in the Bermuda?

“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”. 

Who is the supervisory body for VASPs in the Bermuda?

Bermuda Monetary Authority

What is the Travel Rule threshold in the Bermuda?

USD 1000

How to comply with the FATF's Travel Rule and meet AML requirements

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 with the Travel Rule in the Bermuda?

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

Which regulations are applicable to the Bermudian Travel Rule?

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 about the Travel Rule in the Bermuda?

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.

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