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We refer to the Conyers June 2022 alert in relation to upcoming amendments to the Investment Business Act 2003 (the “IBA”). As noted, the Investment Business (Amendment) Act 2022 was passed on 1 April, 2022 amending the IBA. However, the amendments did not take effect immediately. The Bermuda Monetary Authority has now confirmed the effective date for such amendments will be 27 July, 2022.
What does this mean practically?
Previously exempted entities
Existing Bermuda entities that have a physical office in Bermuda but had previously qualified for and filed an exemption notification will have 12 months to either be licensed under the IBA or be registered as a Class B Registered Person.
Existing entities carrying out investment business
Existing Bermuda incorporated entities that do not have a physical presence in Bermuda but do carry out “investment business” elsewhere will also have a 12 month transitional period to…