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British Virgin Islands and the recent FATF listing

17 Jun 2025
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At its plenary session on 13 June, the Financial Action Task Force (FATF) included the British Virgin Islands (BVI) as a jurisdiction being monitored for the active resolution of identified deficiencies in its regimes for the countering of anti-money laundering, terrorist financing, and proliferation financing. While no significant issues were identified with the BVI compliance regimes, the BVI was given a short list of action items aimed at demonstrating the effectiveness of its compliance regimes, and therefore included on the list of jurisdictions being monitored (FATF Grey List).

In placing the BVI under such monitoring, the FATF stated that it “does not call for the application of enhanced due diligence measures” to the BVI, but members are encouraged to consider the listing in their risk analysis. FinCEN and the EU might consider adding the BVI to their advisory and AML high-risk lists, which may lead to BVI structures having to provide extra due diligence in some cases.

The BVI has consistently demonstrated its commitment to meeting international obligations and remains dedicated to the fight against financial crime in all its forms. It has taken decisive steps in recent years to enhance its compliance regimes, aligning with the Caribbean Financial Task Force recommendations through amendments to key legislation, including the Counter-Terrorism Act, Proceeds of Criminal Conduct Act, and the Criminal Justice (International Cooperation) Act.

When the FATF places a jurisdiction under increased monitoring, it means the country has committed to engaging with the FATF to swiftly resolve the identified strategic deficiencies within agreed timeframes. Other comparable jurisdictions have undergone a similar process. For example, in 2023, the Cayman Islands was removed from the Grey List of jurisdictions after satisfying the FATF’s Recommended Actions.

It is important to note that this FATF decision does not mean that any direct penalties will be imposed by EU member states on the BVI or BVI structures, and this list is not linked with the list of Non-Cooperative Jurisdictions for Tax Purposes published by the EU.

The British Virgin Islands government press release can be found here.