Regulatory Blog

On 26 January 2026, Luxembourg’s Directorate of Registration, Estates and VAT (AED) issued Circular No. 792 quater, setting out AML/CFT identification and verification obligations for professionals under its supervision and replacing Circular 792 ter of 28 July 2025.

The BVI Financial Investigation Agency Act Revised Edition as of 1 January 2020, is a comprehensive legal framework that establishes and governs the Financial Investigation Agency, a statutory body charged with investigating and combating financial crimes within the Virgin Islands. Originally enacted through Act 19 of 2003 and coming into force on 1 April 2004, the Act has undergone several amendments to enhance its scope and efficacy, notably through Acts in 2007, 2008, 2013, 2015, and 2017 (plus the further amendments outlined in detail below).

The BVI Proceeds of Criminal Conduct Act, revised as of 1 January 2020, serves as a foundational legal instrument in the BVI, aimed at dismantling the financial incentives of crime by addressing the recovery and management of assets derived from illicit activities. Originally enacted in 1997, the legislation has undergone numerous and significant updates, as reflected in later amendments and orders such as the 2021 and 2023 Amendments, as well as the Proceeds of Criminal Conduct (Designated Countries and Territories) Order of 1999. Together, these modifications underscore the Act’s adaptability to emerging challenges, particularly in the context of global financial crimes.

The Bermuda Proceeds of Crime Regulations 2008, enacted under the Proceeds of Crime Act 1997 and the Anti-Terrorism Act 2004, establish a comprehensive framework to combat money laundering and terrorist financing within Bermuda. These regulations are divided into four parts, each addressing critical aspects of compliance, enforcement, and operational procedures for relevant entities.

The European Banking Authority recently provided comprehensive advice to the European Commission on six key regulatory mandates under the new Anti-Money Laundering and Countering the Financing of Terrorism framework.

If you are involved in the virtual assets space in the British Virgin Islands, you will want to pay attention to this. In November 2025 the BVI Financial Services Commission released Circular 43, which includes a helpful FAQ document called "Understanding Virtual Assets and VASP Regulation".

On 14 October 2025, the European Banking Authority (EBA) published a comprehensive report on the growing use of white labelling in the financial services sector. This business model, where financial institutions (providers) collaborate with other entities (partners) to offer financial products under the partner's brand, is gaining traction across Europe. Here is a summary of the key insights:

The Government of Bermuda, through the National Anti-Money Laundering Committee (NAMLC), released its 2024 National Risk Assessment (NRA), marking the fourth such assessment. This comprehensive report evaluates Bermuda's exposure to Money Laundering (ML) and Terrorist Financing (TF) risks, providing insights to strengthen national policies and private sector resilience.

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

On 1 December 2025, the Commission de Surveillance du Secteur Financier announced the launch of its 2025 Annual AML/CFT Questionnaire on 23 February 2026. This initiative aims to gather standardised information on money laundering and terrorism financing risks faced by entities under CSSF supervision, as well as the measures implemented to mitigate these risks.

On 9 October 2025, the European Banking Authority released a report addressing money laundering and terrorist financing risks in the crypto-asset sector.

On 8 October 2025, the European Banking Authority released a comprehensive report summarising six years of reviews of the approach of national competent authorities on anti-money laundering and countering the financing of terrorism supervision across EU/EEA Member States. The report highlights significant progress in the following areas: