Regulatory Blog

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:

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.