BCB uses a risk-based reliance model to onboard Corporate Clients into the VAS platform. This model ensures that reliance on a Corporate Client’s own AML/KYC program is only permitted once rigorous due diligence has been performed and contractual agreements are in place.
- Mitigates BCB risk by ensuring Corporate Clients maintain robust AML/KYC practices.
- Enables efficiency & scalability by leveraging clients’ existing compliance programs.
- Supports ongoing compliance through scheduled and trigger-based independent reviews.
- Standards enforcement: Client programs must meet RFI requirements. Where Bermuda regulation is less strict, BCB’s standards prevail.
The reliance model follows a structured onboarding flow:
- Corporate Client VAS Demand Queue
- Incoming client interest is added to a demand queue.
- VAS Expression of Interest
- Client formally expresses interest in the VAS program.
- Client Risk Questionnaire (risk rating)
- Client completes a risk self-assessment.
- Used to calculate an initial AML/KYC risk rating.
- Independent AML/KYC Assessment (as needed)
- Performed where risk level or information gaps require independent validation.
- Scope may include audit methodology, sampling, and testing plans.
- VAS Client Agreement
- Formal contractual agreement between BCB and the Corporate Client.
- Establishes reliance terms for AML/KYC responsibilities.
- Ongoing Independent AML/KYC Assessments
- Conducted at regular intervals, with frequency based on client risk profile.
- May also be triggered outside scheduled reviews.
- Ensures client AML/KYC practices remain compliant and enforceable.