FATF Mutual Evaluation Scorecard

British Virgin Islands

The overall ML/TF understanding in BVI is a bit limited, especially related to foreign legal persons and arrangements. The broad view from key authorities is that there is insufficient nexus between them and the illicit activities in BVI, impacting the effectiveness of AML/CFT system negatively.
While TF risk is considered as being low, regulatory authorities, with their limited resources, have yet to identify the subset of non-profit organizations (NPOs), which are vulnerable to TF abuse and threats.
Banks and legal practitioners have a good understanding of AML/CFT controls, obligations and risks, but there is a notable gap in understanding from the trust and company service providers (TCSP) and investment business sectors, as well as designated nonfinancial businesses and professions (DNFBPs).
Investigations, prosecutions and convictions not proportionate to BVI’s significant corporate and financial services sector.

Since the 2024 MER, BVI has mainly used legislation to improve identified deficiencies, starting with the enablement of risk-based supervision in the NPO sector. Additionally, BVI has taken steps to address TF risks from the NPO sector by establishing a comprehensive mitigation framework, as well as creating outreach and educational programs, and publishing guidance notes and best practices to raise awareness of TF vulnerabilities and mitigation. All these led to an upgraded re-rating of R8.
Significant legislative reforms were also implemented to enhance beneficial ownership transparency, disclosure, reporting and oversight, resulting to an improved rating on R24.
Additional legislative provisions were made on the Securities and Investment, Insurance, and Financial Services Commission Acts to drive improvements on the regulation and supervision of financial institutions, ultimately upgrading the rating on R26.
Last but not least, substantial amendments were made to the Financial Investigation Agency Act and its policy documents to address gaps identified on the MER related to risk-based supervision and framework of DNFBPs, with R28 being re-rated as Compliant.