Regulatory Blog

Following the invasion of Ukraine by Russia, the UK Government, alongside the member states of the European Union, the United States of America and other global stakeholders issued significant new sanctions. View a table of all the sanctions here.

European Union has issued significant and far-reaching sanctions and restrictive measures on Russia and the Russian Economy. View a table of all the sanctions here.

On 20 November 2025, the British Virgin Islands International Tax Authority announced that Economic Substance reporting obligations will transition from the Beneficial Ownership Secure Search System to the Virtual Integrated Registry Regulatory General Information Network portal. The ITA has confirmed that the new VIRRGIN ES filing portal is in its final stages of preparation and will be deployed for filings due in 2026.

The British Virgin Islands introduced its first annual Frozen Assets Reporting process for 2025, aligning with the Virgin Islands’ sanctions framework and UK sanctions legislation. BVI entities, that are in scope for this reporting, are reminded of their mandatory statutory obligation to report frozen assets linked to UK-designated persons.

On 23 October 2025, the BVI International Tax Authority published a notice to advise that the Organisation for Economic Co-Operation and Development introduced significant updates to the Common Reporting Standards, now referred to as CRS 2.0, alongside the development of the Crypto-Asset Reporting Framework.

On 15 October 2025, the UK intensified its sanctions against Russia, targeting key sectors of its economy in response to the ongoing conflict in Ukraine. These measures aim to undermine Russia's ability to fund its military operations while signalling the UK's commitment to global security and peace.

Following the triggering of the snapback mechanism in August 2025 by the UK, Germany and France under the 2015 Joint Comprehensive Plan of Action, the UN Security Council has now reimposed sanctions on Iran. The EU and the UK have also reimposed their own autonomous measures, which are super-equivalent to the sanctions imposed by the UNSC.

Published in June 2025, the Q2 2025 Statistical Bulletin from the BVI Financial Services Commission highlights key updates in the financial services sector:

On 4 July 2025, the BVI Financial Services Commission published its newsletter for Q2 of 2025, highlighting its efforts in advancing regulatory frameworks and promoting financial literacy. Here are the key updates:

The English High Court recently delivered a significant judgment in Thomas, Carter, Nilson v. PJSC National Bank Trust [2025] EWHC 75 (Ch), addressing whether UK sanctions laws would be breached by distributing bankruptcy funds to PJSC National Bank Trust, a Russian bank. This case provides critical guidance for trustees in bankruptcy navigating the complexities of sanctions compliance.

Reporting Financial Institutions and Non-Reporting Financial Institutions in the British Virgin Islands are required to comply with new Common Reporting Standard obligations by 30 September 2025.

The English High Court's judgment in LLC EuroChem North-West-2 and Eurochem Group AG v Societe Generale S.A. and others [2025] EWHC 1938 (Comm) provides crucial guidance on the interpretation of "ownership" and "control" under EU sanctions regulations, particularly in complex corporate structures involving discretionary trusts.