Securities Commission of The Bahamas Examinations Report 2021-2025

EXAMINATIONS REPORT The Commission’s first published report on its examination programme across its full regulatory mandate PUBLISHED DATE: 28 AUGUST 2026 2021–2025

Securities Commission of The Bahamas Examinations Report Page 2 of 19 Securities Commission of The Bahamas All rights reserved. No part of this publication may be reproduced or distributed without the prior written permission of the publisher. This document does not constitute legal advice. This publication is available at www.scb.gov.bs. © Copyright 2026 Securities Commission of The Bahamas

Securities Commission of The Bahamas Examinations Report Page 3 of 19 CONTENTS

1. FOREWORD ............................................................................................................................4
2. INTRODUCTION ......................................................................................................................4
3. THE EXAMINATION FRAMEWORK ...........................................................................................5 3.1 MANDATE AND EXAMINATION TYPES................................................................................5 3.2 THE TWO-STREAM MODEL AND EXAMINATION FREQUENCIES.........................................5 3.3 REPORTING AND SERVICE STANDARDS............................................................................6 3.4 CAPACITY..........................................................................................................................6
4. EXAMINATION ACTIVITY 2021–2025 ........................................................................................6 4.1 TOTAL ONSITE EXAMINATION ACTIVITY ............................................................................8
5. FINDINGS................................................................................................................................8 5.1 FINDINGS ACROSS THE MANDATE....................................................................................8 5.2 AML/CFT/CPF FINDINGS ...................................................................................................9 5.3 CONDUCT FINDINGS.......................................................................................................11 5.4 OPERATIONAL AND PRUDENTIAL FINDINGS...................................................................11 5.5 CRS EXAMINATIONS AND FINDINGS...............................................................................11 5.6 MOST COMMON FINDINGS AND GOOD PRACTICES .......................................................11
6. REMEDIATION AND FOLLOW-UP ..........................................................................................16
7. EXAMINATION PRIORITIES....................................................................................................17 ANNEX A: STATISTICAL TABLES INDEX .....................................................................................19 ANNEX B: GLOSSARY AND ABBREVIATIONS.............................................................................19

Securities Commission of The Bahamas Examinations Report Page 4 of 19

1. FOREWORD I am pleased to present the Securities Commission of The Bahamas’ first Examinations Report, covering the years 2021 to 2025. Examinations are where regulation meets the regulated: they are how the Commission tests, firm by firm and file by file, whether the standards the legislation and broader regulatory framework set are being met in practice. This report is published as part of the Commission’s commitment to transparency and accountability. It explains how examinations are selected, scheduled and conducted; what our examiners found across every category of obligation the Commission supervises; what firms were required to do about it; and what the Commission expects, so that every regulated firm can measure its own arrangements against the practices this report describes. The five years covered here tell a clear story. The Commission more than doubled its annual examination output while conducting onsite examinations across a wide span of its supervised population; its examiners found progressively fewer deficiencies per examination each year even as they tested harder; every finding identified between 2021 and 2024 was fully remediated; and from January 2026 examinations run on a fully risk-keyed, two-stream cycle built for the decade ahead. This report is published alongside the Commission’s AML/CFT/CPF Activity Report 2021–2025, and the Commission intends to publish it annually. Christina Rolle Executive Director 28 August 2026
2. INTRODUCTION This is the Securities Commission of The Bahamas’ first Examinations Report. It covers the Commission’s onsite examination programme across its full regulatory mandate, anti-money laundering, countering the financing of terrorism and countering proliferation financing (AML/CFT/CPF), conduct, operational, prudential and Common Reporting Standard (CRS) obligations, for the calendar years 2021 to 2025, and describes the examination framework as it stands at publication, with instruments or programmes commencing in 2026 expressly dated as such. The report is written for the Commission’s licensees and registrants and their compliance professionals, for the wider industry and its advisers, and for the public. Firms are encouraged to read the findings against their own control frameworks and to act on what they see: the tables in section 5 show where examiners most often find deficiencies, and firms that address those areas before their next examination should expect better outcomes. This report is one of three the Commission publishes about its supervisory work. The AML/CFT/CPF Activity Report 2021–2025 carries the Commission’s full anti-money laundering record, including

Securities Commission of The Bahamas Examinations Report Page 5 of 19 supervision and enforcement beyond the examination programme; AML/CFT/CPF examination figures appear in full in both reports. The Digital Asset Supervision and Surveillance Report (to be published September 2026) carries the fuller treatment of digital asset supervision. Figures in this report are drawn from the Examinations Department’s registers. 3. THE EXAMINATION FRAMEWORK 3.1 Mandate and examination types The Commission examines its licensees and registrants for compliance with the Securities Industry Act, 2024, the Investment Funds Act, 2019, the Financial and Corporate Service Providers Act, 2020 and the Digital Assets and Registered Exchanges Act, 2024, as well as the Financial Transactions Reporting Act, 2018, the Anti-Terrorism Act, 2018 and the sector-level AML/CFT/CPF Rules. The Commission also examines the Common Reporting Standard obligations of its supervised population under its delegated Competent Authority functions. Three examination types are used: routine examinations scheduled by risk; for-cause examinations prompted by adverse information, complaints or credible intelligence; and thematic reviews focused on specific risks or obligations across a population. Desk-based reviews are conducted by the supervision function as part of ongoing offsite supervision and are not counted as examinations in this report. 3.2 The two-stream model and examination frequencies Since January 2026, examinations have run in two streams. Focused AML/CFT/CPF and CRS examinations are scheduled on their own cycle, keyed to each entity’s ML/TF/PF risk rating, so that financial crime coverage is driven by financial crime risk specifically; fieldwork runs one to two weeks depending on the size of the entity’s client base. Full-scope examinations, the stream that tests the conduct, operational, prudential and other non-AML obligations, are keyed to the entity’s overall priority tier (Intensive, Enhanced, Standard or Baseline), the single classification assigned by combining its risk ratings across all supervisory risk dimensions. The two streams carry separate due dates and do not reset one another: a focused examination does not defer a full-scope examination, nor the reverse. Table 3.1: Minimum examination frequencies Stream and band Keyed to Minimum frequency Full-scope: Intensive tier Entity’s overall priority tier Every 24 months Full-scope: Enhanced tier Entity’s overall priority tier Every 36 months Full-scope: Standard tier Entity’s overall priority tier Every 48 months Full-scope: Baseline tier Entity’s overall priority tier Every 60 months Focused AML/CFT/CPF and CRS: High ML/TF/PF risk rating Every 24 months

Securities Commission of The Bahamas Examinations Report Page 6 of 19 Focused AML/CFT/CPF and CRS: Medium ML/TF/PF risk rating Every 36 months Focused AML/CFT/CPF and CRS: Low ML/TF/PF risk rating Every 60 months Higher-risk entities are examined materially more frequently; the minimums are floors, not schedules, and a capacity reserve is held for for-cause work. Deferrals and overrides are documented, and deferral of an entity in the highest intensity tier requires Executive Director approval. The supervision function contributes a pre-examination scoping memorandum for each scheduled examination, with final scope resting with the examinations function. 3.3 Reporting and service standards Examination reporting operates to Board-approved service standards. Final examination reports are approved by the Manager, Examinations within three working days of receipt of the entity’s response to the draft report, or expiry of the response period; reports carrying High severity findings, or identifying candidates for enforcement referral, are approved by the Executive Director; and final reports issue within five working days of that receipt or expiry, directly from the examinations function to the entity. Extension applications are determined within five working days. 3.4 Capacity Onsite examination activity resumed in 2021 following the COVID-19 pandemic, and the examination function was deliberately built in step with the programme it carries: a team of seven full-time examiners delivered the 2021–2023 cycles, growing to 12 members by the end of 2024 and 15 by the end of 2025 (the years in which annual output reached 60 and then 76 examinations), and the Board has approved growth to 30 by the end of 2026, doubling the function again to carry the expanded two-stream programme. 4. EXAMINATION ACTIVITY 2021–2025 The Commission concluded 240 examinations between 2021 and 2025, reaching 240 distinct licensees and registrants, a deliberately breadth-first strategy that carried onsite examination across a wide span of the supervised population within a single five-year window, with recurrence now governed by the risk-keyed cycle under the current methodology. Examination selection tracked the risk profile of the population: in 2024 and 2025 the number of examinations of High-rated entities matched the number of entities rated High in the corresponding year-end population, three and five respectively. The 2025 programme was dominated by thematic reviews consisting of 64 examinations. Additionally, there were four for-cause examinations concluded between 2022, 2023 and 2025.

Securities Commission of The Bahamas Examinations Report Page 7 of 19

Table 4.1: Examinations concluded, by type Examination type 2021 2022 2023 2024 2025 Routine onsite 31 31 40 60 10 Thematic 0 64 For-cause 0 1 1 0 2 Total 31 32 41 60 76 of which entities rated High at selection 0 3 1 3 5 Source: Examinations Department examinations register, by year concluded. The nil 2021 High-risk figure reflects the resumption of onsite work following the pandemic and the nil High-rated population at end-2021. Figure 4.1: Examinations concluded by type, 2021–2025 Source: Table 4.1. Table 4.2: Examinations by scope Scope 2021 2022 2023 2024 2025 Combined (AML/CFT/CPF and other obligations) 31 32 41 60 48 AML/CFT/CPF only 0 6 Non-AML only 0 22 Source: Examinations Department examinations register. Scope-differentiated examinations commenced with the 2025 programme; earlier examinations were conducted on a combined basis. Table 4.3: Examinations by sector Sector 2021 2022 2023 2024 2025 Financial and corporate service providers 8 14 20 44 26

Securities Commission of The Bahamas Examinations Report Page 8 of 19 Securities industry firms 15 18 7 10 34 Investment fund administrators and managers 8 1 12 6 16 Digital asset registrants 0 0 2 0 0 Source: Examinations Department examinations register. Two 2022 examinations of dual-licensed entities are counted once, within the sector of the licence under which the examination was led. Digital asset registrants were first licensed in Q4 2021; the focused AML/CFT/CPF and CRS examination stream operating since January 2026 prioritises digital asset registrants and higher-risk financial and corporate service providers in its selections. Onsite coverage of the digital asset sector in 2024 and 2025 was provided through an externally commissioned focused review of the sector; the focused AML/CFT/CPF and CRS examination stream carries the sector from 2026. 4.1 Total onsite examination activity The tables above count the examinations recorded in the examinations register: examinations of licensees and registrants, the population on which the findings and risk-targeting analysis in section 5 is based. The Commission’s full onsite examination activity is broader, additionally comprising examinations of investment funds (384 across the period) and examinations conducted by authorised agents under the Financial and Corporate Service Providers Act. Table 4.4 states the complete picture. Table 4.4: Total onsite examinations Onsite examinations 2021 2022 2023 2024 2025 Examinations conducted by the Commission’s examiners 31 32 41 40 71 Examinations of investment funds 98 – 170 100 16 Examinations conducted by authorised agents (FCSPA) 7 7 5 20 5 Adjustment for dual-licensed entities recorded under each licence – (1) (2) – – Total onsite examinations 136 38 214 160 92 Source: Examinations Department records. The examinations register, the basis of this report, records the Commission-conducted examinations together with the agent-conducted examinations of 2024 and 2025 (31, 32, 41, 60 and 76 by year). Dual-licensed entities are recorded under each licence held; the adjustment states each such examination once. 5. FINDINGS 5.1 Findings across the mandate Examinations identified 1,687 findings across the period. AML/CFT/CPF obligations account for the largest share in every year, reflecting both the combined scope of most examinations and the intensity with which financial crime obligations are tested; conduct findings form the second largest

Securities Commission of The Bahamas Examinations Report Page 9 of 19 category. The composition of the 2025 year reflects the AML-focused thematic programme conducted in that year. Table 5.1: Findings by category Category 2021 2022 2023 2024 2025 AML/CFT/CPF 82 248 223 267 248 Conduct 113 123 110 86 5 Operational 17 43 22 35 1 CRS 13 7 1 0 23 Prudential 4 13 2 0 1 Total 229 434 358 388 278 Source: Examinations Department breaches register, by year identified and register category. Figure 5.1: Findings by category, 2021–2025 Source: Table 5.1. 5.2 AML/CFT/CPF findings Across the period, the most common AML/CFT/CPF findings clustered in eight areas: i. identification, verification and initial due diligence; ii. ongoing monitoring; iii. MLRO and compliance officer arrangements; iv. training; v. disclosure obligations in respect of terrorist property; vi. customer risk ratings and risk assessments; vii. policies, procedures and controls; and viii. the treatment of politically exposed persons.

Securities Commission of The Bahamas Examinations Report Page 10 of 19 Targeted financial sanctions and sanctions screening, including the annual filing obligations under the country-specific orders made under the International Obligations (Economic and Ancillary Measures) Act, is the most frequently identified category across the period, reflecting the intensity with which those obligations are examined. The full analysis, including the category table by year, appears in the AML/CFT/CPF Activity Report 2021–2025 and reconciles to the figures below. Table 5.2: AML/CFT/CPF findings, by sub-category Sub-category 2021 2022 2023 2024 2025 TFS / sanctions screening 8 81 74 104 105 CDD: identification and verification 17 36 71 20 36 FIU disclosure / STR obligations 1 21 23 26 24 Policies, procedures and controls 3 28 18 26 17 Risk assessment and risk rating 19 20 9 15 19 Training 12 18 10 23 21 Ongoing monitoring 14 12 5 24 12 MLRO / compliance function 4 23 6 17 7 Politically exposed persons 4 6 5 11 7 Source: Examinations Department breaches register. Sub-categorised rows; a small number of register rows recorded without a sub￾category account for the difference from the AML/CFT/CPF line of Table 5.1. The clearest indicator of strengthening compliance is the trend in findings per examination: from its 2022 peak of 7.7, the number of categorised AML/CFT/CPF findings per examination fell in every year of the remaining period, to 3.3 in 2025, over the same period in which annual examination output more than doubled. Figure 5.2: Examination output and AML/CFT/CPF findings intensity, 2021–2025

Securities Commission of The Bahamas Examinations Report Page 11 of 19 5.3 Conduct findings Conduct findings (437 across the period) form the second largest category, concentrated in the years when full-scope combined examinations dominated the programme. The low 2025 figure reflects the AML-focused composition of that year’s thematic programme rather than an improvement of that scale in a single year. Conduct findings are published at category level; the most common conduct findings, with the expected standards and good practices, are set out in section 5.6. 5.4 Operational and prudential findings Operational findings (118 across the period) and prudential findings (20) complete the non-AML record. Operational findings peaked in 2022, consistent with the post-pandemic resumption of onsite testing of business continuity and operational arrangements. As with conduct findings, these categories are published at category level, with the most common findings and good practices set out in section 5.6. 5.5 CRS examinations and findings The Commission exercises delegated Competent Authority functions for the Common Reporting Standard over its supervised population under the Delegation Order made in 2025 and the associated memorandum of understanding of December 2025, comprising compliance monitoring, intelligence, investigation and the application of sanctions under the Automatic Exchange of Financial Account Information Act. CRS obligations are tested within the focused AML/CFT/CPF and CRS examination stream. Examinations identified 44 CRS findings across the period: 13 in 2021, 7 in 2022, 1 in 2023, none in 2024 and 23 in 2025, the 2025 figure reflecting the resumed intensity of focused-stream testing in that year’s programme. 5.6 Most common findings and good practices The most common AML/CFT/CPF findings, with the standard the Commission expects and the practices that meet it well, are set out first; the most common findings in the other categories follow. Category Most common finding Expected standard Good practice AML: ongoing monitoring Ongoing monitoring of client relationships not conducted, or not evidenced on the client files reviewed. Ongoing monitoring must be conducted for every client, at a frequency and depth commensurate with the client’s assigned risk rating. Operate risk-calibrated review cycles, with higher￾risk clients reviewed more frequently and on defined trigger events, and evidence each review on the client file, dated, recording the information considered and the conclusion reached, so that monitoring is demonstrable rather than

Securities Commission of The Bahamas Examinations Report Page 12 of 19 asserted. Report overdue reviews to the compliance function and track them to completion. AML: training Not all employees and directors received AML/CFT/CPF training during the review period. AML/CFT/CPF training must be provided annually to employees and directors alike (regulation 6(2), Financial Intelligence (Transactions Reporting) Regulations, 2001; section 19(2)(c)(iii), Financial Transactions Reporting Act, 2018). Deliver an annual programme that covers directors as well as staff, tailors content to role, and includes induction training for new joiners; test understanding, and keep attendance and assessment records so that participation can be demonstrated for every individual. Brief the board periodically on typologies emerging in the firm’s markets. AML: sanctions filings Annual declarations under the country￾specific International Obligations (Economic and Ancillary Measures) Orders, Iran, Iraq, DPRK and Afghanistan, filed late or not at all. Annual declarations must be filed with the Commission within ninety days of the calendar year end under the Iran and DPRK Orders, and by 31 December each year under the Iraq and Afghanistan Orders (International Obligations (Economic and Ancillary Measures) (Iran) Order, 2019; (Iraq) Order, 2018; (Afghanistan) Order, 2018; (DPRK) Order, 2019) and the Group of Financial Services Regulators (GFSR) Guidance Notes on Targeted Financial Sanctions Reporting Forms. Carry each Order’s deadline separately on the compliance calendar with a named owner, file nil declarations where there is nothing to report, and retain the filing confirmations so that compliance can be evidenced for every Order in every year. AML: FIU disclosures Quarterly Terrorist Property Reports not filed with the Financial Intelligence Unit. Terrorist Property Reports to the Financial Intelligence Unit must be filed quarterly (section 70(3)(a) and (b), Anti￾Terrorism Act, 2018). Diarise the quarterly cycle, file nil reports where required, reconcile each filing to the firm’s sanctions screening outputs for the quarter, and retain the Financial Intelligence Unit’s acknowledgements as evidence of filing. AML: client due diligence Required know-your￾customer and due diligence documentation not maintained on the The prescribed identification and verification documentation must be held on file for every corporate and Use onboarding checklists differentiated by client type, test client files periodically on a risk-weighted sample,

Securities Commission of The Bahamas Examinations Report Page 13 of 19 files of corporate and individual clients. individual client (section 15 of the Financial Transactions Reporting Act, 2018, and regulations 4 and 5, Financial Transactions Reporting Regulations, 2018). remediate legacy gaps through a structured programme, and refresh documentation on cycles tied to each client’s risk rating. AML: client risk ratings Client risk-rating frameworks not aligned with the legislation, or clients not risk-rated in whole or in part. Every client must be risk￾rated under a framework covering all legislatively required risk categories (rules 3 and 4, Financial and Corporate Service Providers AML/CFT Rules, 2019; rule 5, Securities Industry AML/CFT Rules, 2019; rule 3, DARE AML/CFT/CPF Rules, 2022). Rate every client at onboarding and re-rate on defined trigger events, ensure the framework addresses each mandated risk category, and validate it periodically against the firm’s business-wide risk assessment so that client ratings and the enterprise assessment tell one consistent story. The most common findings outside the AML/CFT/CPF category are set out below, together with the standard the Commission expects and the practices the Commission regards as meeting that standard well. Governance findings, five in the period, each concerning the annual review of professional indemnity insurance, are recorded within the conduct category in the register statistics and are shown under their governance theme below. Category Most common finding Expected standard Good practice Conduct Failure to notify the Commission, or to notify it in good time, of notifiable events, including outsourcing arrangements, changes in registered information, the termination of a representative, renewal matters, offering documents, financial reporting matters, the annual audit of an investment fund administrator, winding-up or dissolution, and ongoing statutory reporting obligations. The Investment Funds Act, 2019, the Securities Industry Regulations, 2012, and the legislation governing digital asset businesses and financial and corporate service providers require that the Commission be notified of these matters promptly, and in the specified cases immediately. Maintain a register of the firm’s regulatory notification obligations, mapping each notifiable event to its statutory deadline and to an accountable owner, and operate a documented escalation procedure so that notifiable events reach the compliance function without delay. Treat openness with the Commission as the governing principle: where there is doubt whether a matter is notifiable, notify. Test the notification process periodically and report the results to the board. Conduct Interim and audited financial statements not submitted by the statutory deadline. Interim and audited financial statements must be submitted to the Commission within the Operate a financial reporting calendar with milestones set well ahead of each statutory deadline, engage auditors early enough for the audit

Securities Commission of The Bahamas Examinations Report Page 14 of 19 timeframes the legislation prescribes. timetable to meet the filing date, and escalate emerging delay to senior management while time remains to recover it. Where a deadline nonetheless cannot be met, notify the Commission immediately, before the deadline passes, with the reasons and a firm date for submission. Conduct Client accounting records, or the required declaration of their availability, not maintained. Section 2 of the International Business Companies (Accounting Records) Order, 2016 requires that a declaration of the availability of accounting records be kept at the registered office of an international business company. Obtain the declaration as a standard element of client onboarding, hold it on the client file at the registered office, and verify its presence and currency through periodic sample testing of client files, with gaps remediated and reported through the compliance monitoring programme. Conduct Annual information update and declaration form not filed by the prescribed deadline. Regulation 3 of the Financial and Corporate Service Providers (General) Regulations, 2020 requires the annual information and update form to be filed each year by the prescribed deadline. Carry the filing on the firm’s compliance calendar with a named owner and an internal deadline ahead of the statutory one, verify completion independently of the person responsible for filing, and retain the filing confirmation on the compliance file. Operational Reconciliations not performed within the prescribed timeframe. Regulation 87 of the Securities Industry Regulations, 2012 and section 48 of the Investment Funds Act, 2019 require reconciliations to be completed within the prescribed timeframes. Operate a documented reconciliation schedule with preparation and independent review performed by different people, defined thresholds for escalating aged or unresolved items, and reporting of persistent breaks to senior management. Where transaction volumes warrant it, automate the reconciliation process and reserve manual effort for exception handling. Prudential Required regulatory capital not maintained. Regulation 42 of the Securities Industry Regulations, 2012 requires adequate regulatory capital Recalculate the regulatory capital position formally at least monthly, and monitor it continuously where positions

Securities Commission of The Bahamas Examinations Report Page 15 of 19 to be maintained at all times, not merely at reporting dates. or revenues move materially. Maintain an internal buffer above the regulatory minimum with defined triggers that escalate to senior management and the board before the minimum is at risk, integrate capital planning with business projections, and notify the Commission immediately upon any breach or reasonably anticipated breach. Governance Professional indemnity insurance not reviewed annually. Regulation 43(2) of the Securities Industry Regulations, 2012 requires professional indemnity insurance to be reviewed annually. Place the review on the board’s annual agenda as a standing item, assess the adequacy of cover against the firm’s current profile, the scale and nature of its activities, client base and claims history, rather than simply renewing the prior year’s terms, confirm renewal before expiry so that cover is continuous, and record the board’s assessment and conclusion in the minutes. CRS CRS policies and procedures not maintained. Regulation 3 of the Automatic Exchange of Financial Account Information Regulations, 2017 requires CRS policies and procedures to be maintained. Maintain documented CRS policies and procedures proportionate to the nature of the business, approved at an appropriate level and subject to version control; review them at least every two to three years and whenever the legal or operational environment changes; and train the staff responsible for applying them. CRS Self-certifications not obtained or not held on file. The Automatic Exchange of Financial Account Information framework requires self-certifications to be obtained and maintained on file. Obtain the self-certification at onboarding, as a condition of opening the account, and test its reasonableness against the other information gathered in onboarding; operate a cure programme for pre-existing accounts; monitor for changes in

Securities Commission of The Bahamas Examinations Report Page 16 of 19 circumstance that call the certification into question and obtain a fresh certification where they arise; and retain certifications on the client file, including for seven years after the relationship ends. CRS Information returns not filed. Section 6 of the Automatic Exchange of Financial Account Information Act, 2016 requires information returns to be filed. Maintain a documented methodology for classifying entities and accounts, reconcile the reportable￾account population to onboarding records before each filing, validate returns ahead of the deadline through the AEOI portal, file nil returns where required, and retain filing confirmations. Assign the annual cycle a named owner and carry it on the compliance calendar. 6. REMEDIATION AND FOLLOW-UP Remediation and enforcement operate as concurrent and independent processes; following the issue of an examination report, licensees and registrants are expected to remediate all identified deficiencies within specified timelines, irrespective of whether enforcement action is taken. Remediation is administered by the dedicated remediation function within the Supervision Department, to which examination findings pass under a structured internal findings transfer, on a two-track, severity-driven model: • High severity findings require a containment and risk-mitigation plan within 30 days and full remediation within up to 90 days, with monthly progress reporting; • Medium severity findings must be remediated within up to 180 days, and • Low severity findings within up to 360 days, each with quarterly reporting. Closure is not administrative: remediation is verified against an evidence-based standard before a finding is closed, and follow-up examinations, commissioned from the examinations function, validate remediation where warranted, with failed validation treated as a repeat finding recorded in the examinations register. The remediation record is complete for 2021 through 2024 and current for 2025. A remediation letter was issued to every licensee and registrant examined, covering each finding identified in the examination. Every finding identified between 2021 and 2024 (1,409 across the full mandate) has been fully remediated, and no finding required escalation to enforcement for non-remediation.

Securities Commission of The Bahamas Examinations Report Page 17 of 19 Findings identified in 2025 are within their prescribed remediation timelines, with closure verified under the rolling regime described below. Table 6.1: Remediation outcomes Measure 2021 2022 2023 2024 2025 Examinations concluded 31 32 41 60 76 Remediation letters issued 31 32 41 60 76 Findings subject to remediation 229 434 358 388 278 Findings fully remediated 229 434 358 388 Within timelines Remediation rate 100% 100% 100% 100% – Findings identified in 2025 remain within their prescribed remediation timelines at the date of this report and are verified on closure under the rolling regime instituted in October 2025. Since October 2025, repeat-finding tracking and evidence-based closure verification have operated on a rolling basis in the examinations register, with remediation plan tracking maintained in the remediation function’s records and a shared dashboard between the two departments. In the first partial verification cycle, forty deficiencies were assessed for remediation, eight were verified closed against the evidence-based standard, and none required escalation to enforcement. 7. EXAMINATION PRIORITIES The Commission has produced its annual examination priorities since 2019, informed by the preceding cycle’s risk ratings, so that regulated persons can see where supervisory attention will fall. Since January 2026, focused AML/CFT/CPF and CRS examinations have commenced and operate as a separate stream on their own schedule, distinct from conduct and full-scope examinations, and will continue on that basis going forward, with selections drawn under the examination selection methodology against current entity risk ratings, prioritising digital asset registrants and higher-risk financial and corporate service providers. The 2026 examination programme concentrates on licensee and registrant compliance with AML/CFT/CPF and Common Reporting Standard obligations, consistent with the Commission’s published 2026 priorities and reflecting the areas in which the jurisdiction’s regime is subject to international assessment this year. Since January 2026, focused AML/CFT/CPF and CRS examinations have operated as a separate stream on their own schedule, with selections drawn under the examination selection methodology against current entity risk ratings and digital asset registrants and higher-risk financial and corporate service providers prioritised. A thematic AML/CFT/CPF review will run across all four regimes the Commission administers, focusing on the conduct and quality of self-risk assessments, the risk￾based approach to monitoring, know-your-customer performance, record maintenance, the treatment of politically exposed persons, complaints handling, training, and compliance with

Securities Commission of The Bahamas Examinations Report Page 18 of 19 reporting and filing obligations. On the CRS side, under the delegation effective from November 2025, examinations will test whether firms maintain documented automatic-exchange policies and procedures, keep the required records, have identified their reportable accounts and registered with the Competent Authority, and filed their information returns by the 30 September deadline. The consequence framework escalates alongside: from 2026, financial penalties for cited AML/CFT/CPF breaches are being enforced on an extrapolated basis, with sample-based examination findings extrapolated to the licensee’s full client population and penalties assessed accordingly. Examination capacity is being grown to 30 members by the end of 2026 to carry the expanded programme, the authorised-agent examination channel continues under the Commission’s review, and the repeat-findings measure instituted in October 2025 will mature into a published effectiveness series, against which the Commission will report in the next edition of this report.

Securities Commission of The Bahamas Examinations Report Page 19 of 19 ANNEX A: STATISTICAL TABLES INDEX Table 4.1: Examinations concluded, by type. Table 4.2: Examinations by scope. Table 4.3: Examinations by sector. Table 5.1: Findings by category. Table 5.2: AML/CFT/CPF findings, by sub-category. Figures 4.1, 5.1 and 5.2 are generated from the tables they accompany. ANNEX B: GLOSSARY AND ABBREVIATIONS Term Meaning AML/CFT/CPF Anti-money laundering, countering the financing of terrorism and countering proliferation financing CRS Common Reporting Standard DARE Digital Assets and Registered Exchanges Act, 2024 EXD Examinations Department FCSP Financial and corporate service provider FTRA Financial Transactions Reporting Act, 2018 IFA Investment Funds Act, 2019 MLRO Money Laundering Reporting Officer SIA Securities Industry Act, 2024 STR Suspicious transaction report TFS Targeted financial sanctions