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

Oyster Consulting (Bermuda) Ltd. lecture discussed Bermuda’s new Anti-Money laundering/Anti-Terrorist Finance audit requirements    

Oyster Consulting (Bermuda) Ltd. Consultant Henry M. Komansky, J.D., presented his second CLE lecture to the Bermuda Bar Association on 6th April 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 now mandates that a separate AML/ATF audit be conducted.

“This new requirement for an AML/ATF audit brings Bermuda in line with FATF Recommendation 18 (and its interpretive notes).  The audit requirements are not necessarily onerous but they will be new to most AML/ATF regulated entities in Bermuda.  It is important to realise that the audit requirement applies to all AML/ATF regulated entities, including all those supervised by the BMA under the AML/ATF Regulations as well as Regulated Professional Firms.  I am looking forward to rolling out our audit program which leverages Oyster’s long experience conducting AML Audits for SEC-registered broker-dealers.”

For more information or to schedule an educational luncheon on this or other compliance topics, 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.