The joint Plenary of the Financial Action Task Force ("FATF") and MONEYVAL took place on 12 and 13 June 2025. As part of the Plenary outcomes published on 13 June 2025, the FATF recognised that the British Virgin Islands (the "BVI") has made significant progress on its recommended actions under the BVI Mutual Evaluation Report ("MER") published by the Caribbean FATF in February 2024.
In the Plenary outcomes, the FATF also recognised that the BVI has made a high-level political commitment to work with the FATF and the Caribbean FATF to strengthen the effectiveness of its anti-money laundering, countering terrorist financing and countering proliferation financing ("AML/CTF/CPF") regimes. Pending completion of its recommended actions, the BVI has been included on the FATF's list of "jurisdictions under increased monitoring" (the "Monitoring List"). The inclusion of the BVI on the Monitoring List has no direct consequences for investors or clients using BVI structures.
Compliance to date
By way of background, the MER assessed the effectiveness of the BVI's AML/CTF/CPF measures and compliance with the FATF's 40 Recommendations. In the MER, the BVI was rated as compliant or largely compliant with 36 of the FATF's 40 Recommendations.
No additional requirements
No penalties or sanctions result from being on the Monitoring List. The FATF does not call for the application of enhanced due diligence measures to be applied to jurisdictions under increased monitoring, but members may take into account the information presented below in their risk analysis. For the avoidance of doubt, the BVI is not on the FATF's list of "non-cooperative jurisdictions" or "high risk jurisdictions subject to a call for action", also known as the FATF blacklist. The Monitoring List is also not concerned with tax transparency or international cooperation.
Action plan
In terms of next steps, the FATF has stated that: "The Virgin Islands (UK) will continue to work with the FATF to implement its FATF action plan by:
- enhancing risk-based supervision of TCSPs, Investment Businesses and VASPs;
- ensuring that accurate and up-to-date beneficial ownership information is available to competent authorities and breaches to obligations are sanctioned;
- improving the quality of SARs and ensure that reporting is in line with risk;
- systematically pursuing ML investigations and prosecutions in line with risk;
- increasing the seizure and confiscation of criminal proceeds; and
- operationalising the new asset management framework."
The BVI Government has stated that the BVI is actively working to progress these target areas and expects them to be completed over the next two years, reinforcing the jurisdiction's standing as a secure, reputable international finance centre.
The BVI's action plan and compliance frameworks supporting the target areas already exist and are familiar to industry and clients. The target areas address the continuing effectiveness of the BVI's legal framework, in terms of compliance and enforcement in detecting and deterring financial crime, rather than changing the existing framework.
Significant progress already made
Over the last year alone, the BVI has already made notable progress to strengthen its AML/CTF/CPF measures including by:
- amending or enhancing over 20 pieces of legislation, such as the Anti-Money Laundering and Terrorist Financing Code of Practice and the Proliferation Financing (Prohibition) Act;
- strengthening its beneficial ownership regime by implementing new regulations for improved global information sharing and migrating data to the secure Virtual Integrated Registry and Regulatory General Information Network platform;
- conducting comprehensive risk assessments to identify risks, vulnerabilities and emerging threats, including an updated Terrorist Financing Risk Assessment, a Non-Profit Organisation Risk Assessment and a specific legal persons and legal arrangements risk assessment;
- issuing enhanced technical guidance on crucial areas, including ongoing monitoring, introduced business, beneficial ownership, suspicious activity reporting and the virtual asset service provider (VASP) travel rule; and
- establishing a new Sanctions Unit in the Attorney General's office, led by a dedicated Sanctions Coordinator, and increasing resources allocated to the National AML Coordination Unit.
You can read the original BVI Government's press release here. We will advise further in the event of any updates. Walkers' and Walkers Professional Services' team of experienced regulatory compliance experts are able to assist with all aspects of our clients' needs. Please do not hesitate to get in touch with your usual contact or any of the contacts mentioned below for more information.
