Dear Clients – As you are aware the Global response to the Russia and Ukraine conflict continues to evolve, including the imposition of increasing sanctions and other restrictive measures.
In step with other international sanctions programs, on March 12th, 2022, The Bahamas officially issued directives prohibiting transactions and other activities relating to the financial resources of the Russian Federation and those of certain entities and individuals linked to the Russian Federation.
It has been a busy period of transformation in The Bahamas with the enactment of the (a) Commercial Entities (Substance Requirements) Act 2018, (b) the Register of Beneficial Act (“ROBO”), 2018 and the (c) Investment Funds Act, 2019 among others. These laws are focused on tax residency of key commercial businesses, appropriate, secure and controlled access to beneficial owner information to enable valid law enforcement enquiries and good governance of the securities markets.
An important update was made to our Investment Funds Act in February 2020. This act was a key element to securing confirmation from the European Union (“EU) that Bahamas structures meet the EU “Economic Substance” requirements.