Bermuda -- Enforcement Actions Regulatory Overview
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The Bermuda Monetary Authority (BMA) is the primary regulator for cryptocurrency enforcement in Bermuda under the Digital Asset Business Act (DABA). No specific enforcement actions with named entities, violation details, penalty amounts, or final outcomes are detailed in available sources for the last 3 years (April 2023–April 2026); only general penalty frameworks and one ongoing case involving Bittrex are mentioned.[1][2][6][7]
Key Case: Bittrex Global (Bermuda) Ltd
- Regulator: Bermuda Monetary Authority (BMA).
- Entity targeted: Bittrex Global (Bermuda) Ltd (Class F Full DABA licensee, ceased operations in 2024).
- Violation type: Non-compliance with DABA requirements, including segregation of digital assets in the "Andromeda Omnibus Wallet," Digital Asset Custody Code of Practice (2019), AML/ATF, KYC, and UN Sanctions protocols (identified via 2022 onsite inspections).
- Penalty amount: Not specified in sources.
- Date: BMA concerns raised in 2022 inspections; investigation appointed August 2023 under DABA section 61; Supreme Court ruling May 2025 (Lai and others v BMA); sanction application July 2025.
- Outcome: BMA appointed Teneo FA for investigation; company in liquidation with joint liquidators seeking court sanction for interim distribution to former customers (July 2025 ruling approved steps); UBOs/directors' legal challenge rejected by Supreme Court in May 2025.[6][7]
General Enforcement Framework (No Specific Actions Named)
The BMA can impose:
- Fines up to US$250,000 and/or 5 years imprisonment for unlicensed digital asset business.[1][2]
- Fines up to US$10,000,000 for DABA breaches or non-compliance with BMA directions.[1][2]
- License revocation, public censure, prohibition orders, or court injunctions.[2] No other significant actions (e.g., with penalties or outcomes) from 2023–2026 are identified; Coinbase Bermuda entities were licensed in 2023 with no enforcement noted.[3] Sources lack comprehensive enforcement records.
Source Data
Unlicensed digital asset business: Fine up to **US$250,000** and/or **5 years imprisonment**.[1]
Unauthorized digital asset issuance: Fine up to **US$100,000**, **5 years imprisonment**, or both.[2]
Non-compliance with BMA directions: Fine up to **US$2 million**.[1]
AML/ATF violations (e.g., POCA Regulations): Up to **2 years imprisonment** and/or **US$750,000 fine**; BMA civil penalty up to **US$10 million** per failure.[1]
Bittrex Global Limited (in liquidation) is a Bermuda entity currently subject to Bermuda Court of Appeal proceedings regarding customer crypto assets.
**Violation:** Non-compliance with DABA requirements and **Bermuda Monetary Authority Digital Asset Custody Code of Practice (2019)**, including segregation of digital assets in the "Andromeda Omnibus Wallet"; also AML/ATF and KYC issues.
**Penalty:** No final penalty imposed (court proceedings ongoing as of July 2025 for liquidation sanctions).
**Date:** BMA concerns raised post-2022 inspections; investigation appointed August 2023 under **DABA section 61**.
The Bermuda Monetary Authority petitioned the Supreme Court of Bermuda to wind up Custodian Life, and the court granted the winding-up order with joint provisional liquidators appointed, not Teneo FA, and liquidation proceedings are ongoing.
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