Regulatory Blog

The Registration Duty, Estate, and VAT Authority has clarified that all Alternative Investment Funds, including unregulated AIFs and not limited to RAIFs only, are required to comply with the Anti-Money Laundering and Countering the Financing of Terrorism reporting obligations. These requirements go beyond Reserved Alternative Investment Funds and apply broadly to all AIFs under AED supervision. The AED has also provided guidance on determining if an entity meets the definition of an AIF and therefore falls within scope of the Luxembourg AML Law of 2004. This guidance can be found on the AED’s website.

On 31 March 2025, the Cayman Islands Department for International Tax Cooperation published to the official gazette, its updated lists of Common Reporting Standard Participating Jurisdictions and Reportable Jurisdictions for 2025.

On 7 March 2025, the Bermuda Monetary Authority amended Rule 14 of the Insurance Account Rules 2016 to account for IFRL filers following the adoption of IFRS 17 - Insurance Contracts. This update introduces important changes for commercial insurers preparing financial statements under International Financial Reporting Standards.

On 21 February 2025, the Financial Action Task Force released significant updates regarding jurisdictions under increased monitoring and high-risk jurisdictions subject to a call for action. These updates highlight global efforts to improve anti-money laundering, combating the financing of terrorism, and counter-proliferation financing measures.

On 25 February 2024, the British Virgin Islands International Tax Authority published its updated lists of Common Reporting Standard Participating Jurisdictions and Reportable Jurisdictions for 2025. Both lists were officially gazetted on 13 March 2025.

On 13 March 2025, the Bermuda Ministry of Justice issued AML-ATF Advisory 1/2025, highlighting the need for heightened vigilance when dealing with jurisdictions deemed high-risk for money laundering and terrorist financing. This advisory underscores the regulatory responsibility of AML/ATF regulated financial institutions and other relevant persons under the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008 to strengthen compliance measures in relation to high-risk countries.

On 14 March 2025, the European Commission issued an alert on the high risk of circumvention identified with respect to imports of plywood originating in Russia or Belarus. More specifically, the European Union has previously imposed sectoral sanctions in respect of plywood and plywood-related products originating from Russia and Belarus. This includes prohibitions on the purchase, import, or transfer of such products, as well as restrictions on related services like brokering, logistics, and warehousing. These measures target a significant revenue source for both countries, alongside individual sanctions placed on oligarchs linked to the wood industry.

On 15 March 2025, the EU published in the official journal of the European Union, Council Implementing Regulation 2025/527 which removes four Russian citizens from the list of designated persons provided under Annex I of EU Regulation 269/2014.

The European Commission recently updated its Frequently Asked Questions on sanctions against Russia and Belarus.