All Bermuda entities subject to AML/ATF regulations must appoint a Money Laundering Reporting Officer (MLRO).  With ever increasing regulation, oversight and sanctions in the AML/CFT arena, even firms having a strong compliance regime for AML/CFT and sanctions may still be in need of external support. To help our clients remain efficient and stay ahead of the regulatory curve, Oyster Consulting (Bermuda) provides support in this area with a number of services, including:

  • Appointment as a MLRO on a long-term or short-term basis, which could include the following tasks:
    • Registration of your entity with the Financial Intelligence Agency’s (FIA) online reporting system goAML.
    • Liaison between the regulated entity and the FIA in respect to SAR reporting and Section 16 Notices.
    • Reviewing internal reporting on unusual activity, assessing the information provided, and making a determination whether or not a SAR must filed with the FIA. Once the decision is made, ensure the decision is recorded and supported according to best practices.
    • Maintaining a register of SAR reports.
    • Review and evaluation of client on-boarding and transaction monitoring.
    • Periodic reporting to senior management and the Board of Directors on internal reports and SAR filings to include the development of trends and typologies.
    • Development of training and awareness programmes for all staff levels to raise internal awareness and culture of AML/CFT and sanctions issues.
  • Acting as a firm’s Deputy MLRO.
  • Needs-based assistance on critical AML/CFT and Sanctions Projects and expert support of an existing compliance regime and MLRO.
  • Mentoring/training services for newly-appointed or existing MLROs.