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BVI Issues General Sanctions Licence for Registered Agents

15 Sep 2023
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On 13 September 2023, the BVI Governor issued the Virgin Islands General Licence No. 04, 2023, relating to the maintenance of economic resources, under the Russia (Sanctions) (EU Exit) Regulations 2019. This General Licence provides specific permissions to Registered Agents and Corporate Services Providers in the Virgin Islands.

The General Licence allows Registered Agents and Corporate Services Providers to receive payments from Designated Persons for various purposes, including fees and expenses, Registrar fees, Director fees, Shareholder fees, and government/statutory body fees related to BVI business companies and foreign companies registered under the BVI Business Companies Act, 2004 (Foreign Companies). It authorises these entities to make payments on behalf of BVI business companies Foreign Companies for the same categories of expenses mentioned above.

Payments must refer to services either already provided or currently being provided to a company or foreign company. There are specified limits for certain fees: USD$50,000 for Registered Agent or Corporate Services Provider fees, USD$20,000 for Director fees and USD$20,000 for Shareholder fees per calendar year for each company or foreign company.

The General Licence is valid for a 12 month period.

Entities utilising the General Licence are obliged to report in writing to the BVI Governor, preferably via email to GOVOfficeSanctions.Tortola@fcdo.gov.uk, using the provided form. Reports should be submitted within fourteen days of a payment allowed under the General Licence. Additionally, records of the General Licence usage must be maintained for six years.

Registered Agents or Corporate Services Providers with pending licence applications with the Governor's Office should promptly contact the office if they intend to use this General Licence.

This General Licence introduces essential provisions and reporting obligations for entities operating under it, ensuring compliance with sanctions regulations.

The official publication can be found here.

The details for what the General Licence permits a Registered Agent or a Corporate Services Provider to do may be found here.

The General Licence No. 4 can be accessed here.