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)).

A threshold of $1000 applies to the obligation of the Payee's PSP and the Payer's PSP to verify the information on their respective customers in the case of transfers of funds not made from an account (Sections 23 (4) and 29 (3)). However, the obligation to transmit information applies regardless of the transaction amount.

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

What personally identifiable information must VASPs collect and share for the Crypto Travel Rule in Bermuda?

Beneficiary information:

• Name and
• Account number, but where the beneficiary does not have an account number, it should be replaced with a unique identifier that allows the transaction to be traced to the beneficiary;

Originator information:

• name,
• account number, but where the originator does not have an account number, it should be replaced with a unique identifier that allows the transaction to be traced to the originator;
• One of the following:
  • Address,
  • date and place of birth
  • customer identification number or
  • 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.

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

Yes.

Section 24 Transfers of funds within Bermuda

Notwithstanding regulation 23(1), where both the payer’s PSP and the payee’s PSP are situated in Bermuda, it shall suffice if transfers of funds are accompanied by the account number of the payer or a unique identifier allowing the transaction to be traced back to the payer.

But if the payee’s PSP or a competent authority so requests, the payer’s PSP shall make available to the payee’s PSP, or the competent authority, complete information on the payer, within three working days of receiving that request from the payee’s PSP or the competent authority.

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.

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

Unknown / Not specified.