Regulatory Blog

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.

On 27 November 2025, the Cayman Islands published two pivotal regulations aimed at improving global tax transparency: the Crypto-Asset Reporting Framework and amendments to the Common Reporting Standard. Effective 1 January 2026, these regulations are designed to combat tax evasion and the misuse of virtual assets.

The global regulatory landscape for digital assets is constantly evolving. For entities operating within the crypto space, staying ahead of these changes is paramount. Recent amendments to the Common Reporting Standard by the OECD have significant implications for BVI crypto funds. Understanding these updates is crucial for ensuring compliance and making informed strategic decisions.

Jersey has implemented the Sanctions and Asset-Freezing Amendment Order 2025 (the Amendment Order), which came into effect on 5 December 2025.

The Financial Action Task Force recently published its updated lists of jurisdictions with strategic deficiencies in anti-money laundering and counter-terrorism financing measures.