The first company and incorporated segregated account (ISA) to be registered in Bermuda under the Incorporated Segregated Accounts Company Act 2019 (ISAC Act) have been licensed as insurance companies. Conyers advised on the incorporation of both the ISAC and ISA and their registration as insurers, working closely with the Bermuda Monetary Authority and the Registrar of Companies.

The ISAC Act, which became operative in January 2020, is companion legislation to the Segregated Accounts Companies Act 2000 (SAC Act). Bermuda segregated account companies (SACs) are well known and widely accepted structures that have been used by Bermuda insurance companies for many years.

The first Bermuda ISAC and ISA were registered as a Special Purpose Insurers to run a specialised insurance programme.  An incorporated segregated account structure was chosen for this programme because of the added security and understanding that the separate legal status of each ISA provides.

Conyers has also recently advised on and assisted with the registration of the second Bermuda ISAC, which is not expected to be registered as an insurer or investment fund, demonstrating that there is an interest in this space beyond the major regulated industries and that the Registrar of Companies is willing to register entities that are not interested in operating as an insurer or investment fund as incorporated segregated account companies.

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