Memo

Our Investment Business Memorandum reviews the 2022 amendments to the Investment Business Act (IBA) regime in Bermuda. The principal change to the regulation of investment business by the Bermuda Monetary Authority is the removal of the former licensing criteria, which provided that to be regulated under the IBA the investment business had to be physically based in Bermuda. This requirement no longer applies and the former exemption category no longer applies. There is a transition period for existing businesses to apply to be licensed or registered (as applicable) which expires on 28 July 2023, please therefore read the attached Investment Business Memorandum to determine whether under the revised IBA you now need to apply to be licensed or registered in Bermuda.