BVI funds and regulatory update – April 2025

The BVI FSC recently issued guidance on ECDD relevant to all BVI financial institutions and Designated Non-financial Businesses and Professions (DNFBPs) when managing their internal customer due diligence procedures.

The guidance aims to assist BVI financial institutions and DNFBPs in distinguishing between standard or low risk customer relationships and high-risk customer relationships where ECDD should be collected and provide clarity on what is required of licensees to implement effective ECDD procedures and controls.

The guidance covers important internal compliance recommendations including:

• how service providers can implement effective ECDD controls and procedures
• the importance of having a clear and differentiated approach between ECDD, CDD and where appropriate for lower risk relationships, simplified CDD (SCDD)
• the value of a well-written compliance manual with flexibility to assess the need for ECDD, CDD and SCDD on a case-by-case basis
• the need to undertake for stringent source of wealth and source of funds verification for higher risk business relationships requiring ECDD

Useful topics on ECDD covered in the guidance include: 

• the requirement to conduct ECDD
• examples of challenges encountered by licensees that may impede effective ECDD
• ECDD and beneficial ownership
• countries with insufficient AML / CFT / CPF measures
• new, developing or emerging technologies or products
• source of wealth and source of funds
• helpful tips for conducting effective ECDD
• treatment of politically exposed persons (PEPs)
• filing of suspicious activity reports
• customers derived through introducer relationships
• overarching requirements for compliance

Read the BVI FSC's guidance on ECDD in full:

Guidance: Effective Enhanced Customer Due Diligence Measures

The BVI FSC has issued an investment business guide to the prevention of money laundering, terrorist financing and proliferation financing.

The guidelines have been developed for the benefit of BVI Investment Business Service Providers (IBSPs). They are relevant to any person or entity who is licensed (or is seeking to become licensed) to provide management, custodial or other services in relation to investment business activities or other securities or investment business products operating in or from within the BVI.

The guidelines cover a range of compliance requirements relevant to IBSPs including:

• robust customer due diligence and ECCD procedures
• risks to be monitored by IBSPs and risk assessments
• transaction monitoring
• proper record keeping measures
• reliance on third parties
• targeted financial sanctions and sanction screening
• employee screening

In addition, the guidance provides context regarding the development of risk and compliance frameworks needed to fulfil statutory reporting obligations and conduct risk assessments.

Read the BVI FSC's guidance on AML / CFT / CPF requirements for investment business in full:

Investment Business Guide to the Prevention of Money Laundering, Terrorist Financing and Proliferation Financing