# Bermuda

> Bermuda (Bermuda Monetary Authority · Privacy Commissioner): A travel rule with no minimum, reaching self-hosted wallets. Region: Americas. Attribution required: A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.

Part of the Soda Labs Privacy Hub regulation map, which reads the instruments
themselves rather than summarising the summaries: https://www.sodalabs.xyz/privacy-hub/regulation

## Key facts

- Entry type: Jurisdiction
- Region: Americas
- Subject: A travel rule with no minimum, reaching self-hosted wallets
- Authority: Bermuda Monetary Authority · Privacy Commissioner
- Stance on on-chain confidentiality: Attribution required. A regulated firm must be able to attribute activity to an identified person, and assets or accounts that make that impossible are barred at the licensed perimeter. This is a rule about attribution, not about whether amounts are public.
- Tags: zero threshold, self-hosted in scope, no AEC position, DABA 2018
- Canonical page: https://www.sodalabs.xyz/privacy-hub/regulation/jur-bermuda

## What it actually says

Bermuda restricts no asset by name and still runs the most comprehensive transaction surveillance requirement found in the Americas. There is no minimum value: every virtual asset transfer carries originator and beneficiary information. More unusually, the obligation expressly reaches transfers to self-hosted wallets, where most regimes either carve out an exemption or say nothing at all. Set against that, the regulator has published no position whatsoever on anonymity-enhancing assets, mixers or tumblers, treating everything under the single heading of digital assets. It is a clean illustration of the pattern running through this section: the binding constraint on confidentiality is the transfer rule, not a list of forbidden coins.

## The instruments that matter

- **Digital Asset Business Act 2018**: the licensing framework, with proceeds of crime regulations and 2021 sector-specific guidance carrying the transfer obligations
- **No de minimis at all**: the obligation to transmit transaction information applies to all virtual asset transfers regardless of amount, the strictest threshold located anywhere in this section
- **Self-hosted wallets are expressly in scope**: providers must obtain and record originator and beneficiary information for transfers to self-hosted wallets, which most regimes either exempt or leave unaddressed
- **No position on anonymity-enhancing assets**: the regulator's own digital assets pages contain no mention of privacy coins, mixers or tumblers, and treat all coins and tokens under the single term digital assets

## Sources

- [BMA digital asset supervision and regulation](https://www.bma.bm/digital-assets-supervision-regulation)

## Related entries

- [Bahamas](https://www.sodalabs.xyz/privacy-hub/regulation/jur-bahamas): Issuance of privacy tokens barred, trading not
- [Brazil](https://www.sodalabs.xyz/privacy-hub/regulation/jur-brazil): A named anonymity rule, and a CBDC that could not solve privacy
- [Mexico](https://www.sodalabs.xyz/privacy-hub/regulation/jur-mexico): Anonymity named as the reason to exclude the asset class
- [South Africa](https://www.sodalabs.xyz/privacy-hub/regulation/jur-south-africa): A travel rule that starts at any value above zero
- [South Korea](https://www.sodalabs.xyz/privacy-hub/regulation/jur-south-korea): Identity-maximalist, and exporting the model
- [Argentina](https://www.sodalabs.xyz/privacy-hub/regulation/jur-argentina): Self-custody providers written out of the regime