BVI FSC highlights the importance of ongoing CDD and monitoring
18 May 2026
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On 16 February, the British Virgin Islands Financial Services Commission (BVI FSC) published Industry Circular 5 of 2026, highlighting the critical importance of ongoing Customer Due Diligence (CDD) and transaction monitoring for Financial Institutions (FIs) and Designated Non-Financial Businesses and Professionals (DNFBPs). While initial CDD establishes a foundational understanding of customer profiles and risks, the BVI FSC underscores that ongoing CDD is essential to address changes in customer circumstances or activities.
Key elements of ongoing CDD include:
- Transaction monitoring: Systems must be in place to detect unusual or suspicious activities, flag them for examination, and take appropriate action.
- Customer screening: Regular screening is required to identify changes in customer status, such as becoming a politically exposed person (PEP) or being subject to sanctions.
- Updating CDD information: Customer data must be reviewed and updated regularly, particularly for higher-risk customers or upon specific trigger events.
The BVI FSC encourages FIs and DNFBPs to strengthen compliance by maintaining updated policies, training staff, and utilising available guidance, including FAQs and monitoring frameworks.
If any FIs or DNFBPs require a review of their internal policies and procedures to ensure that they meet the regulatory requirements, please do get in touch with us. We can also provide general regulatory advice to ensure that any FIs or DNFBPs mitigate any deficient CDD areas in their business to offset any breaches being detected.
For more information, FSC Circular 5 of 2026 can be found here
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