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Contributors

Aki Corsoni-Husain
Aki Corsoni-Husain
  • Aki Corsoni-Husain

  • Partner
  • Cyprus
George Apostolou
George Apostolou
  • George Apostolou

  • Partner
  • Cyprus
Chiara Deceglie
Chiara Deceglie
  • Chiara Deceglie

  • Partner
  • Luxembourg
Massimiliano della Zonca
Massimiliano della Zonca
  • Massimiliano della Zonca

  • Senior Associate
  • Luxembourg
Philip Graham
Philip Graham
  • Philip Graham

  • Partner
  • British Virgin Islands
Ayana Hull
Ayana Hull
  • Ayana Hull

  • Counsel
  • British Virgin Islands
Katerina Katsiami
Katerina Katsiami
  • Katerina Katsiami

  • Associate
  • Cyprus
Andrew Knight
Andrew Knight
  • Andrew Knight

  • Partner
  • Luxembourg
Joshua Mangeot
Joshua Mangeot
  • Joshua Mangeot

  • Counsel
  • British Virgin Islands
Mirza Manraj
Mirza Manraj
  • Mirza Manraj

  • Counsel
  • Hong Kong
Elina Mantrali
Mirza Manraj
  • Elina Mantrali

  • Associate
  • Cyprus
Vanessa Molloy
Vanessa Molloy
  • Vanessa Molloy

  • Partner
  • Luxembourg
Andrea Moundi Savvides
Andrea Moundi Savvides
  • Andrea Moundi Savvides

  • Consultant
  • Cyprus
Matt Taber
Matt Taber
  • Matt Taber

  • Partner
  • Cayman Islands
Carolynn Vivian
Carolynn Vivian
  • Carolynn Vivian

  • Group General Counsel
  • Cayman Islands

BVI: New MLRO Notification Form

The BVI Financial Investigation Agency (FIA) is currently seeking to update its records relating to the appointment of a Money Laundering Reporting Officer (MLRO) for all BVI entities regulated for AML/CFT purposes. In this respect, the FIA has issued a public notice and a new MLRO Notification of Appointment Form. While no hard deadline has been provided we understand the FIA expects the MLRO Notification of Appointment Forms to be completed and returned in Q1 2021.

Entities regulated under the following categories are required to complete the FIA form:

  1. Trust and Corporate Service Providers
  2. Banking Business Money Service
  3. Business Company Management
  4. Mutual Fund Business
  5. Insurance Business

Note this includes all BVI investment funds and approved managers.

The completed and signed MLRO Notification form should be emailed to reportingauthoritygroup@fiabvi.vg.

The public notice can be found here.

The MLRO Form can be found here.

BVI: Approved Managers – MLRO reporting to FSC

Separately, in the past few days the FSC wrote to BVI approved managers to remind them of their obligations under the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 (the AML Code) and the Anti-Money Laundering Regulations, 2008 (the AML Regulations) including, but not limited to, the requirement to maintain AML/CFT policies and procedures in keeping with regulation 3 of the AML Regulations.

The FSC requires all BVI approved managers to submit the following no later than 31 January 2021:

  • The name, address, date of appointment and a brief biography of the manager’s MLRO
  • A copy of the manager’s AML/CFT policies and procedures as required by regulation 3 of the AML Regulations

We anticipate the FSC will extend the above requirements to BVI investment funds during the course of 2021.