Bermuda: corporate bank account opening

Obtain registration and constitutional records, the business description, addresses and relevant representatives. The Bermuda registry guide explains the records available from the Registrar of Companies. Request company-held shareholder records where the public products do not disclose ownership.

Owners, management and operators

BMA guidance includes ultimate ownership or control above 25% for ordinary corporate customers, with control interpreted beyond share percentages. Obtain the ownership chain and agreements conferring management or appointment rights. Do not substitute the separate 10% corporate-service-provider threshold for the bank's customer process.

The guidance also requires identification and verification of the relevant chief executive or equivalent for a legal-entity customer. Verify the person acting for the company and their authority, retaining the banking mandate and required resolutions.

Before activity begins

Establish the account purpose and funding and obtain evidence for unusual arrangements. Apply enhanced measures and relevant PEP approvals, and resolve sanctions findings.

The guidance's limited low-risk exception for verification during establishment includes controls on outgoing funds and transactions; it is not an unrestricted permission to operate an unverified account. Record the conditions and completion steps for any exception used.

Review ownership, operators and activity through ongoing monitoring and obtain updated evidence when a material fact changes.