Who is the regulatory authority in Bermuda?

The regulatory authority in Bermuda is the Bermuda Monetary Authority, sometimes abbreviated BMA. The BMA is responsible for overseeing financial institutions, issuing Bermuda’s currency, the Bermudian dollar (BMD), and ensuring the stability and integrity of the island’s financial system. The Bermuda Monetary Authority also plays a key role in enforcing anti-money laundering regulations and developing financial policies to support Bermuda’s economy.

What is the minimum threshold for the crypto Travel Rule in Bermuda?

In Bermuda, the obligation to transmit transaction information applies to all virtual asset transfers, regardless of amount. However, for transfers not made from an account, Payee and Payer PSPs must verify customer information for transactions of $1,000 or more (Sections 23(4) and 29(3)).

What personal data must VASPs collect and transmit under the crypto Travel Rule in Bermuda?

VASPs must collect and transmit the following information for virtual asset transfers:

Beneficiary information:

• Name
• Account number (or, if unavailable, a unique identifier that allows the transaction to be traced)

Originator information:

• Name
• Account number (or, if unavailable, a unique identifier that allows the transaction to be traced)
• One of the following:
  • Address
  • Date and place of birth
  • Customer identification number
  • National identity number

Are there differences in customer PII requirements for cross-border transfers vs domestic transfers within Bermuda?

Yes, the requirements for personally identifiable information (PII) differ depending on whether the transfer is domestic or cross-border.

For domestic transfers within Bermuda, it is sufficient to include only the payer’s account number (or, if unavailable, a unique identifier that allows the transaction to be traced).

However, if requested by the payee’s PSP or a competent authority, the payer’s PSP must provide complete information on the payer within three working days.

For cross-border transfers, full originator and beneficiary information must be included upfront.

What are the requirements for non-custodial or self-hosted wallets in Bermuda?

Bermuda’s regulatory framework does not specify explicit requirements for non-custodial or self-hosted wallets.