Who Should Report
Overview
In Bermuda, the obligation to report suspicious activities related to money laundering, terrorist financing, and other financial crimes to the Financial Intelligence Agency (FIA) extends to a broad range of individuals and entities. This requirement is grounded in the Proceeds of Crime Act 1997 (POCA) and the Anti-Terrorism (Financial and Other Measures) Act 2004 (ATFA).
Who Must Report to the FIA
Under Bermuda law, the following categories are mandated to submit Suspicious Activity Reports (SARs) or Suspicious Transaction Reports (STRs) to the FIA:
1. Financial Institutions
- Banks
- Insurance companies (including long-term insurers)
- Investment service providers
- Money service businesses (MSBs)
- Digital asset businesses
2. Designated Non-Financial Businesses and Professions (DNFBPs)
- Law firms
- Accounting firms
- Trust and corporate service providers
- Real estate agents
- Dealers in high-value goods (e.g., precious metals, stones, luxury items)
3. Other Obligated Parties
- Casino operators
All businesses (including Government Departments)
Any individual or entity who, in the course of their trade, profession, business, or employment, acquires knowledge or suspicion of money laundering or terrorist financing.