Regulatory Blog

The recent enactment of the National Sanctions Implementation Unit Law 2025 and establishment of the National Sanctions Implementation Unit in Cyprus marks a significant milestone in the island’s sanctions enforcement regime.

The British Virgin Islands Financial Services Commission has extended the moratorium on filing fees for certain statutory updates until 31 March 2026, offering continued relief to eligible entities.

On 16 December 2025, Luxembourg’s Commission de Surveillance du Secteur Financier published Circular 25/900, amending Circular CSSF 22/811 concerning the authorisation and organisation of entities acting as UCI administrators.

The BVI Financial Investigation Agency (Returns) Order, 2025, has been published, introducing a structured framework for the submission of returns by Designated Non-Financial Businesses and Professions and Non-Profit Organisations. This Order, effective from 27 November 2025, clarifies reporting obligations and establishes a clear legal context for compliance. The Order, gazetted as Statutory Instrument No. 99 of 2025, formalises these requirements into law.

On 16 October 2025, the European Securities and Markets Authority released its second consolidated report on sanctions and measures imposed in Member States for 2024. Here are the highlights:

If you are involved in the virtual assets space in the British Virgin Islands, you will want to pay attention to this. In November 2025 the BVI Financial Services Commission released Circular 43, which includes a helpful FAQ document called "Understanding Virtual Assets and VASP Regulation".

If you manage or operate a BVI limited partnership, you should take note of an important update from the BVI Financial Services Commission. On 19 November 2025, the FSC published Circular 41, which introduces the Limited Partnership (Financial Return) Order, 2025.

On 19 December 2025, Luxembourg’s Commission de Surveillance du Secteur Financier published Circular 25/901, which became effective the same day. This circular, streamlines and modernises the regulatory framework for Luxembourg's investment funds. By consolidating previous circulars and aligning provisions with practical experience, it establishes a unified and coherent set of rules for Specialised Investment Funds, Investment Companies in Risk Capital, and Part II Undertakings for Collective Investment.

The European Union has intensified its sanctions against Russia's "shadow fleet" in response to its ongoing aggression against Ukraine. Two recent measures highlight the EU's commitment to curbing Russia's revenue streams and addressing its violations of international law.

The Sanctions Order 2025 was published on 12 December 2025 and came into force on 11 December 2025. This updates the sanctions framework that applies across UK Overseas Territories, including the British Virgin Islands, Cayman Islands. The changes are also relevant to, by local extension, to Bermuda.

On 3 December 2025, the Department for International Tax Cooperation announced the activation of the Country-by-Country Reporting functionality on the DITC Portal. This functionality is effective as of 3 December 2025. This update is critical for Multinational Enterprise Groups with Cayman Islands Constituent Entities.

The Cayman Islands Monetary Authority (CIMA) has officially implemented the Virtual Asset Service Providers (VASP) financial returns form, effective 1 December 2025. This form, accessible via the REEFS system under code VFR-051-84, standardises the submission of periodic financial data for entities registered or licensed under the Virtual Asset (Service Providers) Act (2024 Revision).