A consultative paper was issued by the Securities Commission on FCSPA (Fees) Rules 2024. I did not find it user friendly and called into the Commission but was not able to get a definitive response. I will follow up with their legal department and Accounts dept which I was not able to reach. 2025-07-09;
Fee reimbursement still outstanding (Neka to check)
International Organization of IOEAMA - The Security Council urged all licensees and registrants of the Securities Commission of the Bahamas to confirm compliance where there is a hit regarding a sanctioned individual or entities. Licensees and registrants must report to the FINANCIAL Intelligence Unit and to the Director of Legal Affairs at the Office of the Attorney General, Antoinette Bonaby and copy to NIRFC, Dr. Cassandra Nottage.
amended
IOEAMA: Democratic People's Republic of Korea advised on 2024-09-17 that it one entry on its sanctions list, the Vice Chairman of the workers' party of Korea et al. A response sent to Securities Commission regarding our notation of same. 2024-12-04
IOEAMA: We received two notices from the Securities Commission of the Bahamas with regard to documents from the Financial Action Task Force [FATF] dated October 25, 2024 regarding its latest public statements on jurisdictions under increased monitoring to counter money laundering, terrorist financing and proliferation financing.
In response to the Commission we advised that we have noted their public statement and the updates on the various countries progress as it relates to their addressing strategic deficiencies to counter these AML issues and have from our Regulatory Compliance standpoint, we are adhering to local regulatory requirements for due diligence and enhanced due diligence measures and continue to use the risk based approach to AML, Terrorist Financing and Proliferation financing.
We are presently up to date on our reporting. 2025-04-09
The Securities Commission, OED has been duly notified in writing of all notices received by EasyTerms and to date there were no hits to our database 2/25/2025 relative to ISIL (Da'esh and AI-Qaida). To date nothing to report for 4/9/2025
A Short-form was amended for reset and for review every 3 years as our clients are rated in the medium category. ETF is considered low risk due to the nature of its business.
Report completed
Ongoing monitoring/review process.
Customer list for Q1 2025 was sent to Altermize Russell 2025-04-01 by Feli the complete the MLRO report due 2025-04-10. Once completed it will be sent to FIU and copied to ETF. 2025-06-30
Feli was added to the report as she will have to monitor the process and provide the Quarterly Customer List from Excel with a copy to the undersigned for tracking purposes. Ongoing quarterly report
The Securities Commission issued a directive to registrants to conduct Self Risk Assessment. Risk Assessment is done under the FTRA, 2018. We are required under the law to risk rate all clients for prevention of money laundering CFT and PF. This is an ongoing process for all clients.
For the record, I may add that ETF has a good comprehensive risk management system to help mitigate risks and to manage it daily. (Our risk rating template meets the legislative requirements and we have control measures in place to mitigate against any ongoing risks).
The Securities Commission issued a new Risk Assessment directive in October which was completed by Altermize Russell our MLRO and reviewed by senior management prior to being sent to the SCB on November 12th to meet its November 18, 2024 deadline.
Securities Commission issued a notice/directive on the upcoming National Risk Assessment (NRA) Industry Briefing for December 12, 2024. Since Altermize Russell, our MLRO is charged with completing Risk Assessments on behalf of EasyTerms and each company is allowed a maximum of two persons, she and I have registered to attend the deadline being November 26th. We will provide back-to-office reports.
AML Training for all staff will be tentatively scheduled October 15th 2025 to meet our regulatory requirement for all staff to be trained in AML/CFT and PF. This includes all staff. The session will be conducted by Ms. Bullard a lecturer at the Bahamas Institute of Financial Services [BIFS] if she is available and certificates issued immediately afterwards.
A cursory review of AML/CFT questions was given to staff to read, acquaint themselves and then questioned by Peggy to determine their understanding.
As long as these individuals remain on our records as an affiliate with politically exposed persons who are present or past members of Parliament or have some affiliation, they will be continuously monitored on our books.
Ongoing. No new PEPs identified for period April – June 2024
Latest PEP Dr. Melanie G.S. Halkitis investment in Series 31
No recent PEPS from the newly issued Series 34 subscriptions. 2025
In conducting a review in preparation for the June 2025 AML/CFT several names popped up as PEPS. There's no way to identify a PEP unless the individual discloses or if we have personal knowledge.
The captioned Bill was distributed to all Registrants on December 29, 2023 for consultation i.e. comments and response. The Bill is on the Commission’s website. ETF falls under the FCSPA; however, from time to time some of the provisions may affect our business so the SCB is minded to keep all registrants apprised of changes in legislation.
The Bill circulated to management for comment. I requested Guidance Notes from the SCB, which would focus on the substantive changes made.
The amendments were explained at the SCB Industry Brief on March 15th, at the British Colonial Hilton.
Once The SIA Bill has been approved in the lower house, I will circulate same to you.
The SCB introduced the enhanced Compliance and Regulatory Interface (CoRi) once again on January 9, 2024. Accordingly, it is deemed one of their optimal tools and resources for efficient, convenient and safe compliance tool.
I have successfully activated CoRi and can now log into the website. The User Manual which is a step by step guide is still not available currently. I had spoken to our Account Officer Bashar Isaacs who has since resigned and a new officer has been assigned, but I am currently communicating with Sharon Simmons. Depending on what is required, this may require User/Checker capabilities. Sharon is off on leave and I have requested an update from Kyle Thompson to ascertain the status of our data some of which was not inputted since 2023.
Kyle said he will assist and conduct a review of our file.
Our account officer resigned and another two officers assigned to us.
Our info in CoRi is still not updated despite our annual submissions. Additionally any material changes should be reported in terms of staff changes, systems, etc. a follow-up was sent to the SCB bringing to their attention information which has been omitted from CoRi. It should be noted that I am only able to input into certain fields in the portal. The SCB said they will input the data. I wish to bring this up because we are scheduled for an onsite examination.
We are to do a mock field examination which includes all staff to ensure that they can speak to the work of the company, that they are proficient and knowledgeable about AML and MLRO functions.
The first mock was conducted on May 28th by me. The follow up on the MLRO was done by Altermize on May 29th. Another follow-up to be done spontaneously
Ensure that all licenses are prominently displayed.
Policy and Procedure manual to be updated and a duplicate copy be made available for the field examiner.
Designated manager to walk the field examiner through our processes etc.,
Proper office protocol and decorum should be exercised during the examination period.
Rescheduled for after July 2025 upon proper notice
This is a work in progress.
The Securities Commission sent out a Notice on July 2, 2024 to registrants advising that the Bahamas Competent Authority AEOI portal will open for FATCA, CRS & CBC registration & submission on Monday July 8th at 9 a.m. and will close on Friday August 23rd, 2024 at 5 p.m. All Financial Institutions are to continue to check information on their website www.taxxreporting.finance.gov.bs for updates.
The Securities Commission advised of the reopening of the AEOI Portal on October 4th at 9.00 a.m for CRS & CBC tax reporting and TINThe portal was
For queries, send email to helpdesk@taxreporting.finance.gov.bs
The Competent Authority is hosting a Webinar on FATCA, CRS and CBC Automatic Exchange AEOI Reporting Portal 2025-06-24T15:00:00.000Z. If you are interested, let me know so that I can forward the credentials. The Bahamas Competent Authority AEOI portal was opened for FATCA, CRS & CBC for reporting on Monday, 2024-07-08 - Management should have logged into webinar and/or attended the session on 2025-06-24.
The AEOI portal reopened again this month June 2025. A discussion aide for onsite meeting with the industry looked at the AEOI Standard and is now carrying out the second round of AEOI peer reviews to ensure the effective implementation in practice by committed jurisdictions. The focus of these reviews is to determine whether the jurisdiction (i.e. the relevant government and/or supervisory authorities) ensures effectiveness in practice. Onsite visits play a key role in assisting the assessment team to gain an understanding of the implementation in practice and during the visit the team will meet with all relevant government and supervisory stakeholders as well as with representatives from the financial industry. The objective of the meeting with financial industry stakeholders is to obtain its views and experiences in relation to effectiveness.
N.B. It is important to note that it is the jurisdiction's implementation of the AEOI Standard that is subject to assessment and not the participants from the industry. Accordingly, we should be aware that the visit is not an assessment of any particular Financial Institution's compliance or non-compliance with the requirements
Next review 2025-05-01
This is a continuous and ongoing process and is mandated by the FCSPA
In essence the SCB is of the view that "Section 15 of the FTRA requires that a financial institution ensure that records and supporting information are available on a timely basis when required to be disclosed by law. Further, the FCSPA legislation requires records to be kept in such form (and for such periods) as are reasonably necessary in the conduct of business and operation. Please note that as long as the records are readily available, they may be maintained in an electronic format."
The response given should suffice and is on record however, it is to be addressed at our onsite review 2025.
Feli to take carriage of this requirement and to diarize on a timely basis. 12/4/2024
Feli to give a status update on Record Retention as at March 31st 2025
Next review 2025-07-11 (Test run inspection TBA after April 9th )
Onsite examination is critical to the success of the company under the FCSPA. (See Corporate Governance Guidelines, Policies and Procedures)
RK required that following the last onsite examination, ETF received a five [5] rating which place it on a 5 year rotation or due in 2026.
Upon receiving a response, the SCB said they were confused with the request as they did not have us on their watch list presently. I received a telephone call from Tina Wright on February 13, 2024, who indicated that even though we should be on a five year rotation, the onus is on the registrant to advise the SCB that it’s onsite examination is due and not wait for the SCB to notify us. She indicated that ETF management only apprised the SCB after the fact so that [I believe this may have been a few months late] hence it reduced our review time.
ETF will tentatively be scheduled in June 2025. She promised to send us a formal response.
We are awaiting the response from the SCB. Meanwhile, ETF has to prepare itself for its next onsite examination in June 2025.
To date no response received
FIU/AML Reporting by AMR. First quarter report 2024 submitted for review (RK)
Second quarter report 2024 for end of June completed and submitted. RK/AMR
Third quarter report 2024 for end of September completed and submitted RK/AMR
Fourth quarter report 2024 for end of December to be completed by Feli ...FC/AMR 12/4/2024
First Quarter report 2025 in progress
I telephoned the Securities Commission for Sharon Simmons who is on leave due to an accident. I spoke with Kyle Thompson who is in another area of the Market Surveillance dept., but is managing Sharon's desk. I informed Kyle that in checking the SCB's website I did not see our name on the listing of Money Lenders even though I see our competitors listed. He asked if we increased the amount we lend which is over $5,000.00. I indicated that our lending exceeds that. He said our Mapping Form shows us as Pay Day cash advance but if we have increased our lending to over $5,000, we need to provide a variation request in the amount that is issued.
I requested the form to reassess our current status to be classified as a Money Lender. We always submitted and were classified as a Money Lender so this should have been addressed internally by SCB.
Feli to establish a Checklist leading up to the field examination with Timelines for review/completion
See AEOI Portal above with details of some of the things expected during the AML/CFT examination
The record should show that the Securities Commission postponed the onsite AML/CFT/CRS examination of Easy Terms until after July 2025 to incorporate the Common Reporting Standards or CRS conducted by the Global Forum.
The annual reporting to the Securities Commission is due end of January 31, 2025 done.
Our declarations, reports etc., were sent to the Commission January 31st. Some of the information was inputted in CoRi as far as possible.
The complete report was forwarded via email to Sharon Simmons.
The annual fee is due December 31st., but because fee payments are a statutory requirement we normally do not receive any billing and have to refer to the legislation with regard payment. So rather than wait and for any notification from them, it is in our best interest to remit our payment under cover letter to their account. Neka is to remit and provide me with wire details so that it may be included in my declaration.
Management should be aware that All required documents with regard to material changes should be requested from the relative parties i.e. resignations, retirement and new hires. (Compliance is to be apprised and copied at all times)
The latest financial statement and/or interim statement is also to be included for 2023/2024
Organization Chart reflecting the updates of current employees.
The Business License was received April 7th, 2025 and same forwarded on to the Securities Commission.
The increase in Authorized Capital was approved by the Registrar General on April 8, 2025. A copy has been forwarded to the Securities Commission.
I will sit with Feli so that she is aware of the requirements going forward. Ruthie was provided with all of the required documentation which she compiled in a folder for review. If there are any legislative changes, management should be advised, they should review and be acquainted with all the updated changes.
All issues relative to our reporting requirements are detailed in our Regulatory Compliance Policies and Procedures and all staff should be proficient in these requirements.
Updated Financial Statement
The Securities Commission in preparation for the upcoming examination advised that they required KYC on all Board members including
Police Record/Passport
CV
Current address
In addition they require:
'Certificate of Goodstanding which expired April and other documentation being addressed under Complicance
Approved
Peggy E. Knowles
Corporate Secretary/ Compliance Officer
Updated: 2025-06-24