Henry Komansky, JD of Oyster Consulting (Bermuda) Ltd. Presents Continuing Legal Education Lecture

Henry KomanskyOyster Consulting (Bermuda) Ltd. lecture discussed changes to Bermuda’s Anti-Money Laundering/Anti-Terrorist Finance requirements  

Oyster Consulting (Bermuda) Ltd Consultant Henry M. Komansky, J.D., presented a CLE lecture to the Bermuda Bar Association on 17 February 2016 to discuss changes to Bermuda’s Anti-Money Laundering/Anti-Terrorist Financing requirements.

On 1 January 2016, the long-pending Bermuda Proceeds of Crime Amendment Act 2015 became law.  There have been changes made to Bermuda’s Anti Money Laundering/Anti-Terrorist Financing (“AML/ATF”) requirements in a number of areas including: Client Due Diligence (“CDD”), outsourcing of AML/ATF functions, and the consent provisions related to the filing of Suspicious Activity Reports (“SARs”).  The Act also created a new category of Domestic PEP (“DPEP”) and mandates that a separate AML/ATF audit be conducted.

“The regulators in Bermuda are working hard to ensure our AML/ATF regulatory regime is in line with the new FATF 40 Recommendations, and to demonstrate that Bermuda has a culture of AML/ATF compliance leading up to our projected 2018 Mutual Evaluation by the Caribbean Financial Action Task Force. As a result, entities in Bermuda’s regulated sectors are being placed under increased regulatory scrutiny,” said Oyster Consultant Henry Komansky.

Komansky joined the financial services consulting firm in 2015 and brings more than a decade of expertise in international financial services arenas. In addition to his experience as a Chief Compliance Officer, Komansky has extensive depth with AML and CFT regulation as an attorney, a MLRO and as Head of Analysis for the Bermuda Financial Intelligence Agency. Komansky has been called to the bar in the U.S., Bermuda and as a Solicitor in England and Wales. He also has criminal and investigatory experience as a criminal prosecutor and federal investigator in the US.

For more information or to schedule an educational luncheon on this topic, please contact Henry Komansky at henry.komansky@oyster.bm or visit www.oyster.bm.


Oyster Consulting (Bermuda) provides comprehensive compliance, operational, and cost-effective consulting to financial services and related firms. Our team of industry professionals brings highly-integrated industry knowledge and deep, functional expertise to help our clients protect and grow their business, creating simplicity in a complex environment.



Henry Komansky