Beneficial ownership changes for captive insurers
Captives in Bermuda are about to face new compliance rules under the island’s updated beneficial ownership regime, as announced in a webinar sponsored by the Bermuda Captive Network.
“Captives were previously out of scope because they were financial institutions for the purposes of our Proceeds of Crime Act, but now they will be brought into scope,” said Chiara Nannini, director in Conyers’ Bermuda corporate practice.
This means most captives will soon need to work with their corporate service providers to gather and report important ownership information for a new central register, unless they qualify for an exemption.
“So unless you meet the exemption, there will be some contact from your corporate service provider in due course to obtain the information they need to maintain the beneficial ownership register,” Ms Nannini added.
Bermuda is preparing for its next mutual evaluation by the Caribbean Financial Action Task Force, expected in 2026. The last review was completed in 2018. To those ends, the island has spent the past year overhauling its beneficial ownership framework, a key area that the FATF identifies as “the cornerstone of asset recovery”.
In September, the Senate passed the Beneficial Ownership Act 2025, moving the central register from the Bermuda Monetary Authority to the Registrar of Companies and creating penalties of up to $250,000 or imprisonment for false declarations.
There is some breathing room: authorities say no enforcement will begin until June 2026, allowing time for captives and others to get set up. More details and government guidance are expected soon.
