Regulatory Blog

On 28 October 2024, the British Virgin Islands Financial Services Commission and Financial Investigation Agency jointly released new guidance to help financial institutions and designated non-financial businesses and professions manage risks associated with third-party introducers. This guidance is aimed at strengthening compliance with anti-money laundering regulations and related local legislation by offering a structured, risk-based approach.

The Financial Action Task Force recently appointed the Cayman Islands and Senegal as the first guest members under its Regional Bodies' Guest Initiative. This programme, led by FATF President Elisa de Anda Madrazo, invites two to three guest countries from underrepresented regions to participate in FATF meetings and working groups for a year, enhancing global financial security perspectives.

In May 2024 the English High Court issued its judgement in Vneshprombank LLC v Bedzhamov which has helpfully clarified a number of matters relevant to interpretation of the UK asset freeze regime on Russia. The learned judge examines what constitutes a “reasonable cause to suspect” under UK sanctions law – providing important guidance on when suspicion of ownership or control by a UK asset-frozen person may arise, particularly after formal ownership transfers.

The Virgin Islands introduced updates to its Anti-Money Laundering (AML) and Terrorist Financing regulatory framework through the Anti-Money Laundering (Amendment) Regulations, 2024 and the Anti-Money Laundering and Terrorist Financing (Amendment) Code of Practice, 2024.

On 5 August 2024, the Cyprus Securities and Exchange Commission published CySEC Directive R.A.D 282/2024 which amends the CySEC Directive for the Prevention and Combating of Money Laundering and Terrorist Financing 2020. These changes are aimed at enhancing the framework for preventing money laundering and terrorism financing in the Republic of Cyprus.

The Financial Investigation Agency of the British Virgin Islands has signed a Memoranda of Understanding with the Financial Intelligence Units of Guernsey and the Bahamas. These agreements aim to enhance cooperation in the fight against financial crimes, including money laundering, terrorism financing, and proliferation financing.

On 1 August 2024, the BVI Financial Services Commission announced the recent appointment of Ms Lisa Ann Violet as the first Chief Executive Officer of the Virgin Islands Deposit Insurance Corporation. VIDIC, together with the FSC, maintains a co-monitoring partnership in order to safeguard the financial stability of the Territory.

The BVI Financial Services Commission published Industry Circular 24 of 2024 on Financial Action Task Force National Risk Assessment Guidance. The FATF is revising its guidance on National Risk Assessments for money laundering. This update aims to make the NRA guidance more effective, comprehensive, and useful for all stakeholders, including the private sector and civil society.

The Financial Action Task Force released public statements highlighting jurisdictions with deficiencies in their anti-money laundering and counter-financing of terrorism regimes. In response, the BVI Financial Services Commission issued Industry Circular 26 of 2024, advising compliance with these updates.