A segregated accounts company is a company, or an LLC, registered under the Segregated Accounts Companies Act 2000, which may then establish one or more segregated accounts. Assets and liabilities linked to an account are ring-fenced by statute.
At A Glance
| Governing legislation | Segregated Accounts Companies Act 2000 |
| Separate legal person | Yes, the company. Its accounts are not, section 17(1) |
| Liability of owners | As for the underlying company or LLC form |
| Local or exempted | Either |
| Name must contain | “(SAC)” where the Registrar so directs |
| Evidence of registration | Certificate showing the date of registration, section 6(5) |
Key features
A segregated account is not a legal person
Section 17(1) is explicit: the establishment of a segregated account does not create a legal person distinct from the segregated accounts company. The company remains the single legal person; the accounts are statutory cells within it. Beneficial ownership obligations attach to the company.
Liabilities linked to an account are liabilities only of that account. Assets linked to an account are held as a separate fund, available only to meet that account's liabilities and protected from the company's other creditors and interest holders.
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Incorporated segregated accounts companies →
How to register one
- Check you are eligible. Any company engaged in insurance business, or any other company with the approval of the Minister.
- File a notice under section 5, naming the segregated account representative and stating that you have made provision to account for segregated accounts.
- If you have already traded, provide the statutory declaration and evidence of consent from seventy-five per cent in number of prospective account owners and creditors.
- Give notice to creditors and allow the twenty-eight day objection period.
- File and pay. Registration fees and how to pay →
What we check
That the company is capable of complying with the Act and, in the case of a financial institution, that the Bermuda Monetary Authority has no objection.
Records you must keep
- the records the underlying form requires. For a company, a register of members, a register of directors and officers, a register of charges, minutes of proceedings and books of account. For an LLC, a register of members, a register of managers, a register of charges and records of account
- records identifying the assets and liabilities linked to each segregated account, separately from the general account and from one another
Account level records are held by the company and by its segregated account representative, who must be a regulated person or a person approved by the Minister.
One beneficial ownership register, not one for each account
A segregated account is not a legal person, so it has no beneficial ownership register of its own. The company keeps a single register, covering the company.
Beneficial ownership obligations
Every segregated accounts company is subject to the Beneficial Ownership Act 2025. You must take reasonable steps to identify any individual who owns or controls twenty-five per cent or more of the interests or voting rights, or who otherwise exercises ultimate effective control; verify their identity against a reliable and independent source before entering them on your register; maintain a beneficial ownership register; file the required information with us; and update it within thirty days of being notified of a change.
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The beneficial ownership regime: an overview →
What information about this entity is public
A search of the register returns the registered office address, the memorandum of association or certificate of formation, the date of registration, information on charges and previous names, together with the company's registration as a segregated accounts company.
Account level information sits with the company
Information about individual segregated accounts, and about the owners of those accounts, is held by the company and its segregated account representative rather than being returned by a search of the register.
Bermuda's central register of beneficial ownership is not public
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Who can access beneficial ownership information →
Legislation
Segregated Accounts Companies Act 2000 | 2000 : 33 · External link