Regulatory Blog

The British Virgin Islands (BVI) introduced its first annual Frozen Assets Reporting (FAR) process for 2025, aligning with the Virgin Islands’ sanctions framework and UK sanctions legislation. While no standalone notice has been issued, entities in the BVI are reminded of their 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.

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.

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.

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.