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Aki Corsoni-Husain
Aki Corsoni-Husain
  • Aki Corsoni-Husain

  • Partner
  • Cyprus
George Apostolou
George Apostolou
  • George Apostolou

  • Partner
  • Cyprus
Chiara Deceglie
Chiara Deceglie
  • Chiara Deceglie

  • Partner
  • Luxembourg
Massimiliano della Zonca
Massimiliano della Zonca
  • Massimiliano della Zonca

  • Senior Associate
  • Luxembourg
Philip Graham
Philip Graham
  • Philip Graham

  • Partner
  • British Virgin Islands
Ayana Hull
Ayana Hull
  • Ayana Hull

  • Counsel
  • British Virgin Islands
Katerina Katsiami
Katerina Katsiami
  • Katerina Katsiami

  • Associate
  • Cyprus
Petros Kiteos
Petros Kiteos
  • Petros Kiteos

  • Associate
  • Cyprus
Andrew Knight
Andrew Knight
  • Andrew Knight

  • Partner
  • Luxembourg
Joshua Mangeot
Joshua Mangeot
  • Joshua Mangeot

  • Counsel
  • British Virgin Islands
Mirza Manraj
Mirza Manraj
  • Mirza Manraj

  • Counsel
  • Hong Kong
Elina Mantrali
Mirza Manraj
  • Elina Mantrali

  • Associate
  • Cyprus
Vanessa Molloy
Vanessa Molloy
  • Vanessa Molloy

  • Partner
  • Luxembourg
Andrea Moundi Savvides
Andrea Moundi Savvides
  • Andrea Moundi Savvides

  • Consultant
  • Cyprus
Marina Stavrou
Marina Stavrou
  • Marina Stavrou

  • Associate
  • Cyprus
Matt Taber
Matt Taber
  • Matt Taber

  • Partner
  • Cayman Islands
Carolynn Vivian
Carolynn Vivian
  • Carolynn Vivian

  • Senior Associate
  • Cayman Islands

The Financial Services Commission’s AML/CFT policy

The British Virgin Islands Financial Services Commission (the BVI FSC) published its AML/CFT Policy (the AML/CFT Policy) on 19 March 2020.

The AML/CFT Policy was developed as a response to BVI’s AML/CFT National Risk Assessment Report (the Report), published on 3 July 2017. In the Report, the primary risk to the BVI FSC was identified as its inability to effectively supervise its licensees and take appropriate enforcement action where necessary. The Report also highlighted the difficulties that the regulator faces in fulfilling its domestic and international co-operation obligations.

Accordingly, the AML/CFT Policy was designed with the broad objective to strengthen the BVI FSC’s supervisory, enforcement and domestic and international co-operation regimes in keeping with the recommendations contained in the Report. It is expected that these enhanced measures will assist in preventing money laundering and any activity that facilitates money laundering, the funding of terrorists or other criminal activities in or from within the Virgin Islands. 

To achieve the objective of the AML/CFT Policy, the BVI FSC will be focusing on the following strategic areas: supervision; enforcement; promotion of cooperation; and stakeholder awareness and research.

Supervision

Licensees can expect increased monitoring of their verification and identification procedures and general internal AML/CFT regimes.

The measures that the BVI FSC intends to undertake include:

  • enhancing the current risk-based approach to the assessment and management of AML/CFT risks in the financial services sector
  • enhancing risk-based systems and procedures used for the monitoring of ongoing licensee activity to prevent abuse of the financial services sector
  • conducting regular risk assessments of licensees to determine appropriate intervals for supervisory contact
  • periodically reviewing and updating the AML/CFT framework
  • strengthening the analytical, investigative and supervisory capacity of its employees to more effectively regulate and supervise licensees
  • reviewing and addressing all outstanding deficiencies identified in the National Risk Assessment

Enforcement

According to the Policy, the BVI FSC’s approach to enforcement actions against licensees will include:

  • taking effective and appropriate enforcement action with respect to all AML/CFT breaches to ensure compliance with regulatory standards
  • ensuring necessary steps are taken by licensees to prevent breaches of any sanctions regime
  • strengthening the BVI FSC’s capacity to achieve greater effectiveness in identifying and taking enforcement actions with respect to AML/CFT breaches

Promotion of cooperation

Under this strategic area, the BVI FSC intends to continue to enhance relationships with relevant domestic, regional and international authorities and ensure timely cooperation on intelligence matters.

Stakeholder awareness and research

The BVI FSC expects to address this area by facilitating ongoing dialogue with industry stakeholders, professional associations and the public.

The AML/CFT Strategy 2020-2022 supports the AML/CFT Policy. The AML/CFT Strategy sets out the precise manner in which the BVI FSC intends to achieve the objectives of the AML/CFT Policy.

The AML/CFT Policy is accessible here.