The BVI Financial Investigation Agency (FIA) is currently seeking to update its records relating to the appointment of a Money Laundering Reporting Officer (MLRO) for all BVI entities regulated for AML/CFT purposes. In this respect, the FIA has issued a public notice and a new MLRO Notification of Appointment Form. While no hard deadline has been provided we understand the FIA expects the MLRO Notification of Appointment Forms to be completed and returned in Q1 2021.

Entities regulated under the following categories are required to complete the FIA form:

1. Trust and Corporate Service Providers
2. Banking Business Money Service
3. Business Company Management
4. Mutual Fund Business
5. Insurance Business

Note this includes all BVI investment funds and approved managers.

The completed and signed MLRO Notification form should be emailed to reportingauthoritygroup@fiabvi.vg.

The public notice can be found here.

The MLRO Form can be found here.

BVI: Approved Managers – MLRO reporting to FSC

Separately, in the past few days the FSC wrote to BVI approved managers to remind them of their obligations under the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 (theAML Code) and the Anti-Money Laundering Regulations, 2008 (the AML Regulations) including, but not limited to, the requirement to maintain AML/CFT policies and procedures in keeping with regulation 3 of the AML Regulations.

The FSC requires all BVI approved managers to submit the following no later than 31 January 2021:

• The name, address, date of appointment and a brief biography of the manager’s MLRO
• A copy of the manager’s AML/CFT policies and procedures as required byregulation 3 of the AML Regulations

We anticipate the FSC will extend the above requirements to BVI investment funds during the course of 2021.