Regulatory Blog

On 8 July 2025, the European Commission adopted measures to further enhance the European Union's framework for combating money laundering and terrorist financing. These legislative developments introduce a pivotal review clause into the amendment adopted on 10 June 2025, which updated the high-risk third-country listings specified under Delegated Regulation (EU) 2016/1675.

On 18 June 2025, Cyprus published the “Prevention and Suppression of Money Laundering from Illegal Activities (Amendment) (No. 2) Law of 2025” (the Amending Law) in the Official Gazette of the Republic.

On 17 June 2025, the Jersey Financial Services Commission published findings from its 2024 compliance monitoring thematic examination, which assessed firms’ adherence to Principle 3 of the sector-specific Codes of Practice and Section 2 of the AML/CFT/CPF Handbook.

Bermuda's commitment to global security is reflected in the framework laid out in its General Guidance on Countering the Financing of Proliferation of Weapons of Mass Destruction. Developed by the Financial Sanctions Implementation Unit, this guidance outlines the critical responsibilities of individuals and entities in combatting proliferation financing and ensuring compliance with Bermuda’s sanctions regime.

The BVI’s Financial Investigation Agency has notified all reporting entities that, effective 1 January 2026, the filing of Suspicious Activity Reports and Suspicious Transaction Reports must be conducted exclusively through the AMLive Portal. This requirement aligns with section 17 of the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 (as amended), which mandates electronic reporting via a secure system as prescribed by the FIA.

On 11 July 2025, Bermuda’s National Anti-Money Laundering Committee advised that it is seeking feedback on proposed amendments to Bermuda’s Proceeds of Crime (AML/ATF Supervision & Enforcement) Act 1997, Proceeds of Crime Act 2008, and related regulations.

On 10 June 2025, the European Commission revised its list of high-risk jurisdictions under the EU anti-money laundering and counter-terrorism financing framework. EU-regulated entities must adopt enhanced due diligence measures when engaging with the listed countries to safeguard the financial system of the EU.

On 23 June 2025, the Government of the Virgin Islands introduced a policy governing access to the Register of Beneficial Ownership for BVI Business Companies and Limited Partnerships. This initiative aligns with international standards for corporate transparency, anti-money laundering, counter-terrorism financing, and counter-proliferation financing, while safeguarding individual privacy.

On 20 June 2025, the Government of the Virgin Islands published a Proclamation bringing the Proceeds of Criminal Conduct (Amendment) Act, 2025 into force on 6 June 2025. This legislation introduces enhanced measures to combat money laundering, strengthen financial transparency, and facilitate international cooperation.

On 6 March 2025, the European Banking Authority initiated a public consultation on four draft Regulatory Technical Standards as part of its advisory response to the European Commission. These RTS aim to bolster the EU's new anti-money laundering and counter financing of terrorism framework.

The Registration Duty, Estate, and VAT Authority has clarified that all Alternative Investment Funds, including unregulated AIFs and not limited to RAIFs only, are required to comply with the Anti-Money Laundering and Countering the Financing of Terrorism reporting obligations. These requirements go beyond Reserved Alternative Investment Funds and apply broadly to all AIFs under AED supervision. The AED has also provided guidance on determining if an entity meets the definition of an AIF and therefore falls within scope of the Luxembourg AML Law of 2004. This guidance can be found on the AED’s website.

On 21 February 2025, the Financial Action Task Force released significant updates regarding jurisdictions under increased monitoring and high-risk jurisdictions subject to a call for action. These updates highlight global efforts to improve anti-money laundering, combating the financing of terrorism, and counter-proliferation financing measures.