The Bermuda Monetary Authority released its 2025 annual report on June 29 — and it is a technology compliance consultant’s dream.

First, the BMA has asserted its commitment to operational resilience as a top priority to reinforce Bermuda’s reputation as a “world-class jurisdiction aligned with international supervisory expectations”.

Indeed, the BMA’s prescriptions for operational resilience takes the somewhat narrower regulatory oversight of outsourcing, IT and cybersecurity risk management to a whole new level of preparedness and governance.

Second, the BMA has continued to position Bermuda as a global leader in cryptocurrency and digital finance regulation. Both its proposed digital payments framework and its exploration of next-generation oversight framework to ensure that evolving technology is matched with supervisory enhancement are cornerstones to Bermuda’s global success in that market.

The importance of digital payment transformation cannot be underestimated. My work as senior technology counsel to Canada’s digital payment, clearing and settlement infrastructure for two years sought me the vital role that real time financial transactions play in a global economy.

Third, the BMA’s publication of its discussion paper on the use of AI in the financial sectors its regulates sought a clear balance between the highly prescriptive regulation of Europe and perhaps the UK and the comparatively laissez faire strategy of innovation facilitation in the United States.

My previous two part series of articles that I wrote in this publication on AI contracting in July 2025 will remind all of the potential disastrous pitfalls that such positive transformative technology can also present.

Fourth, only a few countries the world have adopted anti-counterfeiting polymer banknotes as their currency of choice. Australia was the first, and I was the chief external lawyer to the Bank of Canada on the second adoption of that tech innovation in the world. It is a complex manufacturing feat and not for the faint of heart.

It is true that the UK soon followed Canada when Mark Carney became the Governor of the Bank of England, but the BMA winning the High Security Printing Latin American Award for the Best New Banknote in 2025 attracted the attention of central banks around the world and shone a highly progressive and positive financial security light on Bermuda.

Last, the BMA has described the several ways in which it is now innovatively using AI to dramatically improve its supervisory ability and outcomes.

So what might be next for the BMA?

What if the BMA offered an expedited licensing application process on a “direct to applicant” basis at a much lower cost, with high agility, accuracy and completeness that created a vast competitive advantage for Bermuda in a globally competitive market?

Since the most successful AI innovations have occurred where exclusively rule-based business processes (exactly like the BMA’s licensing regime) are automated into “direct to user” AI driven business processes and experiences, perhaps the BMA should consider using AI to create a direct to applicant licensing application solution.

That operational AI interface would allow applicants to understand, complete, submit and manage their license applications to the BMA directly “online” without a raft of current intermediaries because of the highly intuitive and supporting guidance and assistance that an AI licensing interface application process can offer.

Would that disintermediate the current role of many financial service licensing lawyers in Bermuda? Well, if the BMA’s AI application solution is successful, the answer could be, “definitely, with few exceptions”.

At the same time, the cost reduction, simplicity of process and reduced time to market for establishing financial services in Bermuda might also track as a very steep positive curve on the competitive chart with other jurisdictions.

If we don’t do so, other jurisdictions might.

• Duncan Card is a technology and privacy compliance consultant, and CEO of The Advisory Group in Bermuda. Duncan is a sought after corporate compliance seminar leader on technology, privacy, outsourcing, cybersecurity and operational resilience compliance. The content of this article is not intended to provide any advice.