When the FATF places a jurisdiction under increased monitoring, it means the country has committed to resolve swiftly the identified strategic deficiencies within agreed timeframes and is subject to increased monitoring. The FATF noted in its announcement that it does not call for the application of enhanced due diligence measures to be applied, de-risking or cutting-off entire classes of customers but instead calls for the application of a risk-based approach. Accordingly, at this time, it is not expected that inclusion on the Grey List will have any direct consequences for investors or clients using BVI structures.
The BVI is actively working to implement targeted measures to address any outstanding deficiencies The aim is to complete such reforms over the next two years. FATF has recognized that the BVI has made significant progress on the Caribbean FATF’s recommended actions under the Mutual Evaluation Report published in 2024.
According to a press release issued by the BVI Ministry of Finance on 13 June 2025, an updated National Strategic Action Plan, detailing completed actions and remaining milestones, will be published to provide stakeholders with full transparency on the BVI’s progress. It was noted that significant progress has already been made over the past year including:
- amending or enhancing over 20 pieces of key legislation such as the Anti-Money Laundering and Terrorist Financing Code of Practice and the Proliferation Financing (Prohibition) Act;
- strengthening of the beneficial ownership regime by implementing new regulations for improved global information sharing and migrating data to the secure Virtual Integrated Registry and Regulated 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;
- issuance of 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
- establishment of 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.
BVI government officials have expressed confidence in the jurisdiction’s ability to complete the required reforms within the two-year time period as planned and to maintain the BVI’s reputation as a trusted international finance centre.
