The BVI FSC publishes its priorities and expectations for the 2026 Compliance Inspection Program

• The Compliance Inspection Program will run from March 2026 to February 2027 with a focus on the trust corporate service providers, investment business and virtual assets service providers sectors.

• The program will assess both the design and effectiveness of licensees' internal control frameworks, in particular internal controls, internal audit functions, staff training arrangements and suspicious reporting procedures.

• The BVI FSC expects licensees to comply with legislation, prudential standards and other best practices and may take enforcement action for non-compliance.

On 27 April 2026, the BVI Financial Services Commission (the 'BVI FSC') published a press release on its Compliance Inspection Program for 2026 (the 'Press Release'). 

What is the BVI FSC's Compliance Inspection Program? 

The BVI FSC is the regulatory and supervisory authority for the financial services sector in the British Virgin Islands (the 'BVI') and uses its Compliance Inspection Program as a key supervisory tool to assess, monitor and better understand the risks presented by BVI licensed entities. 

What period will the 2026 Compliance Inspection Program cover? 

The 2026 Compliance Inspection Program will run from March 2026 to February 2027.

Which sectors will the Compliance Inspection Program focus on? 

In it envisaged that the 2026 Compliance Inspection Program will initially target 50 licensees (a 25% increase as compared to the 2025 program) with a focus on the higher risk trust corporate service providers, investment business and virtual assets service providers sectors. Of the 50 identified licensees, 17 will undergo a full-scope anti-money laundering, countering the financing of terrorism and proliferation financing ('AML/CFT/CPF') review due to the elevated risks they present. In addition, the 2026 Compliance Program will include 18 prudential assessments of licensees in sectors associated with increased operational risks, such as banking, investment business, money services business and financing business. All 50 inspections will include an AML/CFT/CPF component. A further 10 or more licensees may be added to the program in response to emerging or evolving risks. 

What approach will the BVI FSC take when conducting the 2026 Compliance Inspection Program? 

The BVI FSC will take a risk-based approach when conducting the 2026 Compliance Inspection Program to ensure that supervisory efforts are proportionate to licensees' risk profiles and reflective of sectoral vulnerabilities.

What are the core areas of assessment for the 2026 Compliance Inspection Program? 

During the 2026 Compliance Inspection Program, the BVI FSC will assess both the design and effectiveness of licensees' internal control frameworks with a particular focus on internal controls, internal audit functions, staff training arrangements and suspicious reporting procedures (further information on how these areas will be assessed is set out in the Press Release). The Press Release notes that licensees will be expected to demonstrate that policies and procedures are not only documented but are effectively embedded within their operations and, when implemented, are sufficiently robust to allow for the mitigation of relevant risks.

Are there any sector specific concerns that will be assessed in the 2026 Compliance Inspection Program? 

The BVI FSC has identified several sector-based vulnerabilities specific to the trust and corporate service providers, investment business, banking, financing business, money services business, virtual assets service providers and insurance sectors (which are detailed in the Press Release) that will be assessed as part of the 2026 Compliance Inspection Program. 

What are the BVI FSC's expectations in relation to compliance? 

The BVI FSC expects licensees to take proactive steps to ensure compliance with legislation, prudential standards and best practices and, where necessary, strengthen their compliance frameworks to achieve this. Where deficiencies or instances of repeated non-compliance are identified, the BVI FSC may take proportionate and dissuasive enforcement action.

Will the findings of the 2026 Compliance Inspection Program be shared with industry? 

At the conclusion of the 2026 Compliance Inspection Program, aggregate information on the findings of the program and potential recommended actions will be shared with industry to provide added guidance on how to improve compliance.

How can Walkers help? 

Walkers' team of experienced regulatory compliance experts is able to assist with all aspects of our clients' needs, including BVI FSC compliance inspections. Please do not hesitate to get in touch with your usual contact or any of the contacts mentioned below for more information.