Dear Readers: I was very disturbed by the article published in Forbes on April 3, 2007 and referred to last week in The Royal Gazette accompanied by the Finance Minister’s defence of Bermuda’s reputation. Here is my reply to Mr. Steve Forbes, editor of Forbes magazine. I haven’t decided yet if I should send it to him. Send me your vote is you think I should.

Dear Mr. Forbes:

>RE: The recent article in your magazine (04.03.07 by Daniel Fisher) entitled, “Pirate Destinations: Hot Money, Where to put it— with the comments, and then there is Bermuda and its laissez-faire approach to taxes and regulation has drawn in much of the world’s reinsurance business—that thrives on secrecy and minimal oversight.” As the world’s leading offshore international financial centre, we are not reputationally deserving of the casual ‘laissez-faire’ comments made in this article.

Perhaps, a bit of illumination and equitable perspective is in order.

Situated 600 miles off the Cape Hatteras, Bermuda is the fourth most remote spot in the world and the oldest British colony in the western Hemisphere. We are a highly civilised country, having had the English Parliamentary system of laws and government since the early 1600s — 100 years before the United States even flexed it baby muscles and staggered its way into becoming a full-fledged autonomous nation.

Our governmental infrastructure is rigorous and vigilant. Through the support of the Bermuda Monetary Authority, an independent oversight regulatory body, and Acts of Parliament, we have long implemented significant modern legislature for policy controls: The Proceeds of Crime and Anti-Money Laundering Act, the Bermuda Investment Business Act, The Trust Act, The Pension Act, The Companies Act, and many other pieces of legislature refining our total transparency operation structure for the entire financial services industry.

Bermuda has four licensed and heavily regulated banks that service our domestic and international population. Anonymous brass door private banks escaping public scrutiny are not solicited and are not allowed to operate in Bermuda.

In late 2001, Bermuda was one of the first jurisdictions to embrace the United States Internal Revenue Service directive for Qualified Intermediary Status. In a simplistic fashion (for we note that is the way your article was written), with this edict, the Bermuda government and major financial and professional institutions here agreed to fully comply with extensive oversight and participation in the Know Your Client (KYC) regime.

All clients, whether individual, corporate, trust, and partnerships, and the like wishing to participate in Bermuda’s investment infrastructure must comply with KYC rules by providing appropriate information on identity, authenticity, legal residence, domicile, sources of revenue, kinds of beneficiaries, trustees, settlers, grantors and so on.

The cost for prevention of money laundering and terrorist activities is burdensome and prohibitively expensive, yet Bermuda institutions’ willingly acquiesced to this information directive, as well as compliance with an US Internal Revenue Service audit every three years.

Imagine the United States allowing a foreign country’s revenue agencies to not only review all US financial institutions records, but regulate part of their financial polices and procedures as well?

While Bermuda has had these Know Your Client policies implemented for more than five years now, many US financial institutions were much later in introducing these same vetting processes to their own global customers.

When speaking of hot money, right on American soil, who can forget the so-called Russian mob money and Colombian cartel-connected accounts that flowed through a couple of very large banks in New York. And does anyone remember the elite client bank (Rigg) scandal in Washington that ruined the careers of several politically connected individuals and that was actually closed down by bank regulators due to an almost total lack of compliance and client verification procedures?

Bermuda has a highly qualified workforce. There are thousands of credentialed professional employees, who on an individual basis themselves are bound by Codes of Ethics from their own licensing and regulatory bodies.

Chartered Financial Analysts — the largest group per capita in the world is situated in Bermuda, employed across the spectrum of financial and insurance/reinsurance services.

Certified Public and Chartered Accountants, 800 to 1,000 are employed by the United States ‘Big Four’ public accounting firms, Ernst & Young, Deloitte Touche, KPMG and PricewaterhouseCoopers, along with various smaller regional firms in Bermuda.

Certified Public Accountants (licensed in the United States) and Chartered Accountants, holding licenses from Canada, the United Kingdom, and various other countries are united by their strict adherence to codes of conduct and professionalism.

Globally based and highly skilled Bermuda law firms with international reputations and multiple country bases employ another 1,000 attorneys that routinely liaise with OECD country professionals, the evolving Far East as well as the triangle star nations of the US, Canada, and United Kingdom.

Many of these attorneys have served in prestigious overseas law firms throughout the world, contributing to a growing body of legal opinions on the ever-evolving ‘flat world’ legal landscape.

Two Bermudian international legal experts, Alec Anderson and Peter Pearman, both with impeccable global reputations in the trust and estate areas, have contributed an entire chapter in the Lexis Nexis Matthew Bender publicatioI>International Estate Planning by Henry Christensen III. <$>

Additionally, Certified Financial Planners|0x99|, CLU’s, ChFC’s, Certified Fraud Examiners, numerous compliance officers and other licensed professionals dot the landscape of pink cottages and sea vista harbours in far more concentrated numbers than would ever be seen in a small town of comparable size in the United States.

Wall Street in Bermuda is on Bermudiana Road where the majority of our US publicly listed (and UK, German exchange listed) companies are domiciled. Many of the 41 listed companies are global names: Ace Ltd, Jardine Matheson Holdings, MAXRe, Partner Re Ltd, Xl Capital, IPC Re, Aspen, AIG. And no, these are not corporate inversion companies. Many of them incorporated here more than 20 years ago. They fully comply with of all US (and other country) regulatory, securities laws, filing their SEC regulatory information in tandem with the global financial analysts that track them.

Sarbanes-Oxley was implemented in short order when the chief executive officer of Ace, Brian Duperreault, led off the CEO public signing of the Ace financial statements.

They are good corporate citizens and meet their global risk obligations, responsibly and promptly. They have paid their bills for Katrina and the other tragic hurricanes of 2004 and 2005, to the tune of some $20 billion.

Standard and Poor’s rating service with total confidence, recently affirmed Bermuda’s sovereign credit rating at AA (positive) long-term and A-1+ (stable) short-term, a higher grade than some major US publicly traded firms and significantly above other islands mentioned by you.

This prized global credit rating privilege is paid for by the residents of Bermuda from our government assessed payroll and consumption taxes. In May, the International Monetary Fund will pay a visit to the island to review our legal, financial, and regulatory infrastructure. We expect nothing less than an extremely high quality rating on the state of fiscal health from them also.

The Bermuda Stock Exchange, founded in 1971, is a full member of the World Federation of Exchanges (formally the FIBV) the BSX has been acknowledged by its peers to meet the highest regulatory and operational standards. Similarly the US Securities Exchange Commission recognises the BSX as a ‘Designated Offshore Securities Exchange’ (DOSM) and the UK Financial Services Authority (FSA) recognises the BSX as a ‘Designated Investment Exchange’ (DIE).

Today, the BSX is the world’s largest offshore, fully electronic securities market offering a full range of listing and trading opportunities for international and domestic issuers of equity, debt, depository receipts, insurance securitisation and derivative warrants.

The Gross Domestic Product of Bermuda is now the highest in the world. Our residents have mandatory pensions , accrued and non-distributable until retirement age, as well as health coverage for every full-time employee in the workforce. With more than 45 million US residents without health coverage, and the US savings and retirement plans at an all-time low, there is no comparison between how our two countries’ governments care for their citizens. Need I say more?

Bermudians may be descended from such buccaneers but in the 20th century, we conduct sophisticated international business in an open transparent competitive environment. Would that you had used your excellent journalistic background, Mr. Fisher (Yale Fellowship, Bloomberg reporter, etc.) to report the real facts?

Nevertheless, it is not too late. We invite you to hop on a plane and see for yourself. After all, under current US tax law, you can still write-off the whole trip as a business expense, except for the 50 percent deduction for meals and entertainment!

Failing that, Mr. Fisher, please do understand this. Bermuda does indeed have a reputation, an impeccable sterling one. We have earned it.

You owe us an apology.

Dear Mr. Forbes — you got it all wrong