Lucy Frew
Partner
Cayman Islands
Nov 19, 2025

Key takeaways
As announced by the Government of the British Virgin Islands (the 'BVI') on 4 November 2025, the Caribbean Financial Action Task Force (the 'CFATF') has published the 2nd Enhanced Follow-up Report in relation to the BVI (the 'Report'). The Report recognises the significant progress the BVI has made to strengthen its anti-money laundering, counter-terrorist financing and counter-proliferation financing ('AML/CTF/CPF') framework since the BVI Mutual Evaluation Report (the 'MER') was published in February 2024.
As detailed in the Report, the CFATF has upgraded the BVI's technical compliance rating in relation to four of the FATF's 40 Recommendations. The BVI is now rated as compliant with Recommendation 28 (Regulation and Supervision of DNFBPS) and largely compliant with Recommendation 8 (Non-Profit Organisations), Recommendation 24 (Transparency and Beneficial Ownership of Legal Persons) and Recommendation 26 (Regulation and Supervision of Financial Institutions). Consequently, the BVI is now rated as compliant or largely compliant with all of the FATF's 40 Recommendations, which is a level of compliance that very few of the EU member states, G20 members or other FATF members currently meet.
The Report evidences the BVI's commitment to implement the recommended actions outlined in the MER and its determination to maintain its reputation as an international financial centre with the highest global standards in relation to AML/CTF/CPF. However, as the Report only considers the BVI's technical compliance rating in relation to the FATF's 40 Recommendations and does not analyse progress made by the BVI since the MER to improve its level of effectiveness, the BVI will remain in the FATF's enhanced follow-up procedure based on effectiveness ratings with the next enhanced follow-up report due in November 2026. A key aim for the BVI is to be removed from the FATF list of "Jurisdictions under Increased Monitoring" and the Report is an important milestone in this journey.
In relation to the Report, the BVI Attorney General has said 'This is an important step in our journey towards achieving full compliance and alignment with the recommended actions outlined in our Mutual Evaluation Report. Our focus now is on ensuring that we maintain the current pace of progress, implementing measures which will strengthen our financial system and allow us to more effectively tackle financial crime'.
Authors
Partner/Cayman Islands
Partner/British Virgin Islands
key contacts
Partner
British Virgin Islands
Senior Associate
Singapore
Vice President
British Virgin Islands
Global Head of AML Services
Cayman Islands
Senior Vice President
Ireland