Regulatory Blog

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.

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.

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.

The BVI Financial Services Commission published the presentations from the 2025 Meet The Regulator Forum. The forum focused on Beneficial Ownership transparency, stakeholder consultations and policy updates.

The UK Overseas Territories and Crown Dependencies have updated their sanctions lists to align with the latest UK measures against Russia.

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.

The BVI’s Financial Investigation Agency has notified all reporting entities that, effective 1 January 2026, the filing of Suspicious Activity Reports and Suspicious Transaction Reports must be conducted exclusively through the AMLive Portal. This requirement aligns with section 17 of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 (as amended), which mandates electronic reporting via a secure system as prescribed by the FIA.

The British Virgin Islands and Cayman Islands are leading jurisdictions for establishing regulated trustee businesses. Their regulatory oversight, tax-neutral environments and innovative trust structures continue to attract individuals and entities seeking to operate within a well-regulated trust framework.