Effectiveness ReviewPresenter: Shauna MacKenzie Director, Legal Services & EnforcementBermuda Monetary Authority

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Institution’s Due Diligence

Customer Due DiligenceAnnual Independent audit

Compliance OfficersQualifications/fitness and proprietyNotify the BMA of changes

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Operations of Regulator

Operations of RegulatorMore AML examinations

Onsites - more identification of risks - Offsites with profile and

statistics

Domestic Cooperation and Communications – FIA/ BPS

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Training

1. More SAR’s – more attention to high networth investors

2. CDD Quality of copies

- consistent list of documents for recordsID verification – need to procure documents to verify wealthGuidance for ultimate beneficial ownerGreater sensitivity to layering practicesClear updating on PEP’sEquivalent Countries

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3. Smaller entities – ongoing monitoring of transactions

How to apply risk based in P & P’s 0 need to delve more into international risk assessment work on other countries – ICRG

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Any queries?