BVI entities: 30 November 2025 frozen assets reporting deadline approaching
21 Nov 2025
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The British Virgin Islands (BVI) introduced its first annual Frozen Assets Reporting (FAR) process for 2025, aligning with the Virgin Islands’ sanctions framework and UK sanctions legislation. BVI entities, that are in scope for this reporting, are reminded of their mandatory statutory obligation to report frozen assets linked to UK-designated persons.
Key reporting details for BVI:
- Who must report: Any BVI person or entity holding, controlling or managing funds or economic resources of UK-designated persons. This includes assets located both inside and outside the BVI.
Note: Assets frozen solely under other sanctions regimes (eg, OFAC) are excluded. - Reference date: Close of business on 30 September 2025.
- Submission deadline: Reports must be submitted by 30 November 2025.
How to file:
- Persons to whom this reporting is relevant are required to report the details of the frozen assets by competing and submitting to the Sanctions Unit within the Attorney General’s Chambers the relevant parts of the compliance reporting form using Parts A and C (frozen assets) and Annex II, here or by using the dedicated frozen assets reporting template, here circulated by the Sanctions Unit with the notice of this reporting obligation. A link to the Sanctions Unit notice dated 20 November 2025 can be found here.
- Submit completed forms to the Sanctions Unit, Attorney General’s Chambers via email: sanctions@gov.vg.
- Refer to the Virgin Islands Sanctions Guidelines for detailed instructions on freezing obligations, reporting standards, and required supporting information:
Sanctions Guidelines (Revised December 2024)
Compliance Reporting Form
Key considerations:
- Reporting frozen assets is a statutory requirement under BVI sanctions legislation.
- Failure to report or submitting inaccurate reports may constitute an offence.
- Entities should maintain robust screening processes and promptly freeze any funds or economic resources of designated persons.
Stakeholders must:
- Review their client base and accounts for any exposure to UK-designated persons.
- Confirm that asset-freezing controls are operating effectively.
- Prepare the report: Start gathering the data as of 30 September 2025 and submit the required report by 30 November 2025.
- Seek guidance if you are unsure about your reporting scope or obligations.
If you need assistance to determine if your BVI entity is in scope of this reporting requirement, please do feel free to get in touch with us. Stay compliant and ensure your reports are submitted on time to avoid penalties.
Post updated: 28 November 2025
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