Regulatory Blog

On 16 December 2025, Luxembourg introduced draft bill No. 8669, a significant legislative proposal set to modernise the incorporation of private limited liability companies. The reform introduces greater flexibility for founders by allowing the deferred payment of the minimum share capital.

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.

The Government of Bermuda, through the National Anti-Money Laundering Committee (NAMLC), released its 2024 National Risk Assessment (NRA), marking the fourth such assessment. This comprehensive report evaluates Bermuda's exposure to Money Laundering (ML) and Terrorist Financing (TF) risks, providing insights to strengthen national policies and private sector resilience.

On 18 November 2025, the European Supervisory Authorities officially designated critical Information & Communication Technology third-party providers under the Digital Operational Resilience Act. This milestone strengthens the EU's financial sector's operational resilience by ensuring robust oversight of key ICT service providers.

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).

On 3 December 2025, the European Commission officially added Russia to its list of high-risk jurisdictions with strategic deficiencies in anti-money laundering and counter-terrorist financing frameworks. This decision follows the adoption of Delegated Regulation (EU) 2025/1393, which aims to amend and assess the EU AML list based on a review of third countries not listed by the Financial Action Task Force but whose membership is suspended.

On 3 December 2025, the European Commission put forward a comprehensive package of legal proposals designed to address Ukraine's ongoing budgetary and defence requirements for the years 2026 and 2027. These measures are presented as a strategic investment in European security and a mechanism to facilitate a fair and sustainable peace.

The BVI Financial Services Commission announced a temporary measure to help Registered Agents manage the current high volume of regulatory filings. On 26 November 2025, the FSC published Circular 44, which grants overseas offices of Registered Agents temporary access to the VIRRGIN Lite platform for Beneficial Ownership and related filings throughout December 2025.