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Customer due diligence

Anti-Money Laundering (AML) and Anti-Terrorist Financing (ATF)

You may receive requests for information or documentation.

Why is BF&M asking for documentation?

BF&M is required to identify and verify the institutions and individuals to whom we provide our services. We perform these functions to serve the customer and protect BF&M, and Bermuda as a whole, from any financial crime. When you provide us with identification, this allows us to provide you with the best possible services in accordance with local requirements, and to verify that information
you are providing us is authorised.

As with all documentation, some items can expire and become invalid due to the length of time that has passed. Local regulations specifically the Proceeds of Crime (AML ATF Financing) Regulations 2008, which can be found on the Bermuda Laws website, detail that we must identify and verify (a certified/notarised valid photo identification document and utility bill) all customers and ensure the information is up to date and accurate before any services have commenced, are maintained or any forms of payments are disbursed. Identifying and verifying are not limited to forms of photo identification, but must now fulfill Know Your Customer (KYC) scope.
In order to comply, we may typically ask you for documentation covering:

  • Identification and verification of all clients and ultimate beneficial owners pertaining to a policy/annuity or service. In relation to an organisation, all formation documentation including connected parties (i.e. Directors, Signing Authorities, Controlling individuals/entities).

  • Geographic factors (all nationalities and citizenships, domiciles, residential address). For organisations, registered office, operating jurisdictions, principal address, etc.;

  • Clients’ source of funds and source of wealth (evidence of such);

  • Ongoing client information and activities (continuously updated over time);

  • Maintenance of relevant due diligence documents on file;

  • Reasons you are conducting business with us;

  • Your local nexus;

  • Your tax reporting requirements;

  • For organisations, the nature of your business;

  • Any further information that will help assess information in relation to the prevention of money laundering and terrorist financing.

If BF&M fails to comply with the local financial crime legislation, we can face criminal proceedings and/or financial penalties. Under these circumstances financial crime prevention legislation requires us to delay our fiduciary obligations (civil) if we cannot apply customer due diligence measures in accordance with the provisions of the Proceeds of Crime (AML ATF Financing) Regulations 2008. Therefore if we cannot apply customer due diligence measures BF&M will be required to:

Reg. 9 (1)
“not open a policy or carry out a transaction for the customer, shall not establish a business relationship or carry out an occasional transaction with the customer and shall terminate any existing business relationship with the customer”

We strive to work with you and/or the organisation to prevent any disruption to the services provided, however our first responsibility is to the local laws and regulations in the prevention of financial crime which include all predicate offences (indictable offences).



  • Criminal proceedings: Formal criminal charges
  • Know Your Customer (KYC): This is the process of a business verifying the identity of its clients and assessing potential risks of illegal intentions for the business relationship.
  • Personal data: Means data relating to an identified or identifiable person who can be identified directly or indirectly
  • Predicate offences (indictable offences): Crime that the prosecutor can charge by bringing evidence of it to the grand jury. Which include:
    • Insider trading and market manipulation.
    • Piracy; and

    • Forgery;
    • Extortion;
    • Tax related crimes (related to direct taxes and indirect taxes, evasion);
    • Smuggling; (including in relation to customs and excise duties and taxes);
    • Robbery or theft;
    • Kidnapping, illegal restraint and hostage-taking;
    • Grievous bodily injury;
    • Environmental crime;
    • Counterfeiting and piracy of products;
    • Counterfeiting currency;
    • Fraud;
    • Corruption and bribery;
    • Illicit trafficking in stolen and other goods;
    • Illicit arms trafficking;
    • Illicit trafficking of drugs;
    • Sexual exploitation, including sexual exploitation of children;
    • Trafficking in human beings and migrant smuggling; (forced labour);
    • Terrorism, including terrorist financing;
    • Participation in an organised criminal group and racketeering;

For more information

Further information on documentation requirements associated with Anti-Money Laundering/Anti-Terrorist Financing or with data protection policy, can be found at the sites linked below: