Frequently Asked Questions
Get answers to common questions.
What is the Financial Intelligence Agency (FIA)?
The Financial Intelligence Agency (FIA) is Bermuda’s national financial intelligence unit, established under the Financial Intelligence Agency Act 2007. The FIA operates as an independent agency with statutory authority to receive, collect, store, analyse, and disseminate financial intelligence relating to suspected proceeds of crime and the financing of terrorism.
Information is primarily received through Suspicious Activity or Transaction Reports (SARs/ STRs) and may be disseminated to relevant domestic law enforcement agencies and overseas financial intelligence units, in accordance with Bermuda’s legislative framework.
What does the FIA do?
The FIA’s core mandate is to protect Bermuda by contributing to the global effort to deter, detect, and disrupt money laundering (ML), terrorist financing (TF), and related financial crimes.
Key functions include:
- Receiving and analysing SARs/STRs
- Requesting additional information where necessary to enhance analysis;
- Producing financial intelligence relating to suspected criminal conduct, including ML and TF;
- Disseminating intelligence to domestic law enforcement agencies, competent authorities, and overseas FIUs, where statutory thresholds are met.
What is a Suspicious Activity Report (SAR)?
A Suspicious Activity Report (SAR) is a disclosure submitted when a person or organisation knows, suspects, or has reasonable grounds to suspect that funds or activity may be linked to money laundering or terrorist financing.
SARs provide law enforcement with critical early-warning intelligence and help safeguard the financial system from abuse. Submitting a SAR may also protect individuals and organisations from inadvertently facilitating criminal conduct and ensures compliance with statutory reporting obligations.
What is a Suspicious Transaction Report (STR)?
A Suspicious Transaction Report (STR) relates to a financial transaction, or series of transactions, that gives rise to reasonable grounds for suspicion of criminal conduct.
Transactions may be considered suspicious where they are inconsistent with a customer’s known business profile, personal circumstances, or expected transactional behaviour. Understanding the customer and the purpose of the relationship is critical to identifying unusual or suspicious activity.
When should I submit a SAR?
A SAR should be submitted as soon as practicable after knowledge or suspicion arises.
The obligation to report applies on a case-by-case basis and depends on the nature of the suspicion and the relevant legislation, including the Proceeds of Crime Act (POCA) and anti-terrorism legislation.
It is important to understand that criminal property is fungible. Even a small amount of illicit funds can contaminate otherwise legitimate assets. For example, depositing illicit funds into an account holding lawful funds may result in the entire balance being treated as criminal property for money laundering purposes. Where appropriate, legal or regulatory advice should be sought.
When do I need to file a SAR with the FIA?
You need to file a SAR as soon as practicable if, in the course of your job or business, you know, suspect, or have reasonable grounds to suspect that money or assets are linked to criminal activity or money laundering—whether the activity has occurred, is ongoing, or was attempted.
Can anyone file a SAR?
Yes. Any individual or organisation may submit a SAR if they have knowledge or suspicion of money laundering or terrorist financing and the information came to you because of your job, profession, or business role.
Who does the FIA share information with?
The FIA operates at arm’s length from law enforcement and other public authorities. Where statute allows, the FIA may disseminate financial intelligence to competent authorities, including but limited to:
- Bermuda Police Service (BPS)
- Bermuda Customs
- Attorney-General’s Chambers
- Bermuda Monetary Authority (BMA)
Internationally, the FIA is a member of the Egmont Group of Financial Intelligence Units and exchanges information with overseas FIUs in accordance with the law when there is a nexus to criminal activity.