• AML/CFT/CPF Examination Form

    AML/CFT/CPF Examination Form

  •  All companies or persons dealing in life insurance and investment-related business, in particular in The Bahamas are subject to Anti-Money Laundering (AML), Countering the Financing of Terrorism (CFT) and Countering Proliferation Financing (CPF) legislation, which include submitting to examinations by virtue of Section 3(1)(b) and Section 3(1)(h)(iv) and (v) of the Financial Transactions Reporting Act, 2018. These include:

    “a company carrying on long term insurance business as defined in Section 2 of the Insurance Act, Chapter 347 or insurance business as defined in section 2 of the External Insurance Act, Chapter 348” or such other business as the Minister may designate by notice published in the Gazette…”;

     Or

     “any person whose business or a principal part of whose business consists of

    …dealing in life insurance, and insurance business which is investment related”;

     Or

     “any person whose business or a principal part of whose business consists of…providing financial services that involve...investment related insurance and money changing”.

    The Insurance Commission is responsible for the management and administration of the AML/CFT/CPF examination process for all insurance companies.

     

  • Revised: June 2026

  • Instructions

  • What is the purpose of this form?
    The purpose of this form is to assess the level of compliance of financial institutions with the requirements of Bahamian AML/CFT/CPF laws and rules.

  • Who should complete this form?
    This form may be used by the Insurance Commission and Independent Auditors approved to act as agents of the Commission in the conduct of on-site Examinations. This form may also be used by a senior staff member of a financial institution for the purpose of an off-site examination.

  • Please confirm your role:*

  • Routine On-Site Examination

  • Routine Off-Site Examination

  • Notes for the Examiner
    1. Examiners are reminded that all examinations are risk-based. The examination should not be completed if the financial institution has not categorized its facilities into low, medium and high risk for money laundering and terrorist financing. A copy of the institutions risk assessment should be available for review. Please advise the Commission immediately if an assessment and categorization of risks has not been completed.


    2. Facilities in connection with a pension scheme taken out by virtue of a person’s contract of employment or occupation are exempted from Know Your Customer (KYC) verification and should not be included in the records examined. All other facilities are to be examined.


    3. Upon completing the examination form, the examining accountant must immediately submit the completed examination form to the Insurance Commission of The Bahamas no later than four (4) months after the financial year end.


    4. The examination year follows the calendar year commences 1st January and ends 31st December of the same year.


    5. Definition of key terms on the examination form can be found on Page 3 of this form and a sampling guide can be found on Page 4.


    6. Persons should refer to the sampling guide when determining the amount of facilities to be examined.

  • Definition of Key Terms

    These definitions are intended only for the purposes of completing this Examination:
  • AML Anti-money laundering
    Cash Notes and coins in any currency including postal orders, cheques of any kind including
    traveler’s cheques, bankers’ drafts, bearer bonds, bearer shares and virtual currency,
    coins, paper money, traveler’s cheques, postal money orders and other similar bearer type negotiable instruments.
    CFT Countering the financing of terrorism.
    CPF Countering proliferation financing.
    Facility Any account or arrangement that is provided by a financial and corporate service provider to a client and by, through or with which the client may conduct two or more transactions whether or not they are so used. A facility also specifically includes: provision of facilities for safe custody, such as safety deposit boxes; investment related products such as annuities and mortgages.
    Facility Holder The client and any person who is authorized to issue instructions in relation to how
    transactions should be conducted through a facility, provided by the financial and
    corporate service provider.
    Large Cash Transaction Refers to any cash transaction of $15, 000 or more that is conducted by a facility holder or a non-facility holder; in relation to any facility held by an insurer. Examples of this may be where:
    • A facility holder pays a sum in cash in excess of $15,000 to the insurer to be applied for the benefit of himself; or
    • A facility holder pays a sum in cash in excess of $15,000 to the insurer to be applied for the benefit of a non-facility holder; or
    • A facility holder pays a sum in cash in excess of $15,000 to the insurer to be applied for the benefit of another facility holder; or
    • A non-facility holder pays a sum in cash in excess of $15,000 to the insurer to be applied for the benefit of a facility holder.
    ML/TF Money Laundering and Terrorism Financing
    PF Proliferation Financing
    FCSP A licensed Financial and Corporate Service Provider
    FCSPA The Financial and Corporate Service Providers Act, Ch. 369
    FTRA The Financial Transactions Reporting Act, 2018
    FTRR The Financial Transactions Reporting Regulations, 2018
    FIU The Financial Intelligence Unit
    FI(TR)R The Financial Intelligence (Transactions Reporting) Regulations, Ch. 367
    Intermediaries A broker, agent, sub-agent or salesperson
    Transaction Any deposit, withdrawal, exchange or transfer of funds in cash, by cheque, payment order or other instrument, and includes electronic transmissions of funds.

     

  • Sampling Guide

  • This guide is for the specific use of examiners performing anti-money laundering and combating the financing of terrorism and proliferation financing examinations on behalf of the Insurance Commission.

    The examiner should ensure that the majority of facilities examined should be from the medium and high risk
    categories.

    The examiner should use this guide to determine the number of facilities that should be examined during an examination, given the total number of facilities managed by a financial institution.

    The sample of facilities examined should only be taken from financial transactions conducted within the last five (5) years.

     

    # Facilities  Percentage Minimum/Maximum Number Examined
    1 - 50  30%  3/15
    51 - 100  25%  12/25
    101 - 200  20% 20/40 
    201 - 300  15% 30/45 
    301 - 500  10% 31/50 
    501 - 700  6% 35/49 
    701 - 1,000  6% 42/60 
    1,000 - 1,500  5% 50/75 
    1,501 - 2,000  4% 60/80 
    2,001 - 5,000  2% 40/100 
    5,001 - 10,000  1% 50/100 
    10,001 - 25,000  .5% 50/125 
    > 25,000  .25% * 

  • Part I: Particulars of the Business

  • Format: (000) 000-0000.

  • Branch Details

  • Does the business have a branch or branches?*
  • Are the client accounts of branches combined or separate?*

  • Personnel Details

  • Part II: Risk-based Customer Verification Procedures and Records

  • 1. Does the company have a documented risk assessment?*
  • 1b. Has the company categorized facilities into Low, Medium and High risk for money laundering and terrorist financing showing the criteria used for such categorization?*

  • Note to the Examiner
    If you answered "No" to any of the questions above, you should not proceed with this examination.  The financial institution should now categorize its facilities into either Low, Medium or High risk for money laundering or terrorist financing.

  • Rows
  • 3. Has each facility holder examined been verified in compliance with the financial institution's policies and procedures for customer identification and verification?*
  • 4. Was enhanced due diligence carried out on any of the facility holders examined?*
  • Rows

  • Part III: Transactions Record Keeping Procedures

  • Rows
  • 9. Are transaction records in written format, or in a form readily accessible and convertible to the English Language?*

  • Part IV: Suspicious Transaction Reporting Procedures

  • 11. Has the MLRO been approved by the Commission?*
  • 12. Has the MLRO confirmed he/she is aware of his/her responsibilities under the FTRA, 2018 and FI(TR)R, Chapter 367?
  • 13. Is the MLRO registered with the FIU?*
  • 13a. If “Yes”, what is the date of registration? *
     - -
  • 15. Has the CO confirmed he/she is aware of his/her responsibilities under the FTRA, 2018 and FI(TR)R, Chapter 367?*
  • 16. Has the Compliance Officer been approved by the Commission?*
  • Rows

  • Part V: Training and Staff Awareness Procedures

  • 18. Does your company have an AML/CFT/CPF Policy and Procedure Manual?*
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  • 19. Is there a policy manual for AML/CFT/CPF staff training?*
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  • 20. Has any staff participated in AML/CFT/CPF training sessions conducted either locally or internationally during the examination period?*
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  • 21. Does the company conduct AML/CFT/CPF training for its intermediaries (i.e. agents, brokers, subagents, and salespersons)?*
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  • 22. Does the company conduct AML/CFT/CPF training for its Board of Directors?*
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  • 23. Do the Insurance Commission’s Guidelines form part of the AML/CFT/CPF training and awareness procedures for staff?*
  • 24. Do internal AML/CFT/CPF compliance reviews take place?*

  • Part VI: Politically Exposed Persons (PEPs) and High-Risk Individuals

  • 26. Does the financial institution have a process for identifying politically exposed persons (PEPs)?*
  • 27. Does the financial institution utilize any screening tools for high-risk individuals?*

  • Part VII Sanctions Screening

  • Sanction Screening Supporting Documentation

  • The following is a list of documents that may be requested during the examination:

    • Copies of the last three UNSC sanctions notices received from the Commission;
    • Evidence of screening conducted in response to each notice;
    • Management reports or compliance logs demonstrating completion of the screening exercise; and
    • Records of any positive matches, potential matches, false positives, and their resolution.

  • Screening Execution

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  • Record-Keeping and Audit Trail

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  • Timeliness and Response to Matches

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  • Part VIII: General Comments

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  • Part IX: Signature

  • Examination Date*
     - -

  • Evaluation Process for Examinations

  • When an auditor has completed an examination of a financial institution/insurance company, the auditor is required to submit the examination form to the Insurance Commission (the Commission). The Commission will then:

    After an AML/CFT/CPF examination form is completed, the Commission’s Examiners evaluate the financial institution’s level of compliance by assigning a score to specific questions on the form. FIs that score points of 95% to 100% are given a rating of “Good” while FIs that score less than 80% are given a rating of “Very Poor”. The table below illustrates the rating system for examinations.


    Rating System for Examinations

    Rating Good Acceptable Poor  Very Poor
    % Points 95% - 100% 90% - 94% 80% - 89%  < 80%


    Examinations which are rated Poor or Very Poor reveal that a financial institution is not in compliance with AML/CFT/CPF laws. Poorly rated financial institutions are informed about their specific deficiencies and a follow-up examination is arranged to address the weak areas.

    During a follow-up examination, the financial institution is given advice on corrective action that must be taken to bring the institution in full compliance with AML/CFT/CPF laws. The entire follow-up process is completed after all plans for corrective action are discussed and executed by the financial institution.

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