T  +441 242-3128


C  +441 537-4782


F  +441 296-6778



Koshea Scott-Millett

Attorny and Senior Compliance Consultant

Ms. Bascome has more than a decade of experience in financial services and is the founding partner of ADL Compliance Limited. She began her career as a Management Accountant for the Government of Bermuda, where she led a team responsible for the processing of accounts payable and accounts receivable for the then-largest Ministry. Her experience with the Government involved both strategic planning and management of the budgetary process, including monthly variance analysis, meetings with heads of departments and Ministerial reporting.

In 2007, Ms. Bascome joined the Bermuda Monetary Authority (BMA) as a Senior Analyst in the Banking, Trust and Investment department. In this capacity, she reviewed license applications, assessed the fitness and properness of directors and shareholder controllers, led prudential meetings with senior management and conducted on-site inspections. Her portfolio included trust companies and stand-alone investment providers for which she monitored liquidity positions, assessed records and systems, and made judgments on the adequacy of insurance coverage.

Ms. Bascome is a qualified anti-money laundering (AML) professional and has worked at two of Bermuda’s largest banks performing trust management, trust and investments compliance. As a Compliance Manager, her responsibilities included assessing clients’ sources of wealth vis-à-vis money laundering and terrorist financing risk, customer due diligence and enhanced due diligence vetting, and ongoing monitoring of customer risks (i.e., occupation, politically exposed person status, country risk, reputational risk, sanctions, etc.). Ms. Bascome has designed and implemented key risk indicator analysis, reporting findings to the senior management and group management teams on a quarterly basis.

Ms. Bascome has extensive knowledge and experience in client remediation projects, client file reviews, regulatory onsite preparation, manual and electronic transaction monitoring, compliance and AML/ATF training, creating/reviewing/revising policy and procedure manuals, AML/ATF audits, gap analysis, compliance officer and money laundering reporting officer (MLRO) duties.

She holds a Bachelor of Business Administration degree with a double major in Finance and Real Estate from Temple University, Fox School of Business and Management, Philadelphia, USA. She is a member of the Association of Certified Anti-Money Laundering Specialists (ACAMS), the current Secretary of Bermuda Association of Licensed Trustees (BALT) and a current executive member (former Treasurer) of the Association of Bermuda Compliance Officers (ABCO).