Oyster Consulting (Bermuda) Ltd. Presents AML Audit/Sanctions Lecture



Oyster Consulting (Bermuda) Ltd Consultant Henry M. Komansky, J.D., presented another in his very popular series of lectures on 7th September 2016 discussing the new requirement under the Bermuda Proceeds of Crime Amendment Act 2015 for AML audits as well as sanctions, with a focus on UK and Bermuda laws and regulations.

On 1 January 2016, the long-pending Bermuda Proceeds of Crime Amendment Act 2015 became law.  The Act now mandates that a separate AML/ATF audit be conducted. For the next few months Henry will conduct a series of Lunch and Learn sessions dedicated to all aspects of anti-money laundering audit processes, procedures and compliance. He will be focusing on the new requirements for all AML/AFT regulated entities (i.e. the requirement by law to have an AML Audit each year). This annual requirement must be met by a variety of entities including Corporate Service Providers, Trust Companies, High Value Dealers, a number of Law and Accountancy Firms, and Real Estate Agents.

“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.  The use of sanctions has been around since the Peloponnesian War, but in March 2016, the UK created a new body to oversee UK sanctions enforcement, the Office of Financial Sanctions Implementation (OFSI), and we should expect some enforcement actions from the new body.”

For more information or to schedule an educational luncheon on this or other compliance topics, please email Training@Oyster.bm or complete our contact form and one of our associates will be happy to help you.


Oyster Consulting (Bermuda) Ltd 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.