Industry Circular 8 of 2025 - Virgin Islands Sanctions Guidelines Updated

Virgin Islands Sanctions Guidelines Updated

Tortola, British Virgin Islands - The BVI Financial Services Commission (the FSC) and the BVI Financial Investigation Agency (the FIA) announce the publication of the updated Virgin Islands Sanctions Guidelines.

The Virgin Islands Sanctions Guidelines (the Guidelines) have been updated to clarify reporting requirements under the newly established Virgin Islands Sanctions Unit (the SU) within the Attorney General’s Chambers. It further sets out the expanded role of Competent Authorities and Law Enforcement Agencies and the expansion of legislation in relation to the application of sanctions measures. 

The Governor of the Virgin Islands, as the Competent Authority responsible for the implementation of financial sanctions measures under the sanctions regimes, has the power (among other things) to delegate certain functions. The Guidelines provide details of the powers and functions delegated to the Attorney General’s Chambers (AGC) in relation to the receipt and processing of licensing applications, as well as the issuance and enforcement of general and specific licences under the U.K. Sanctions Regime. The Governor has also delegated certain specific investigative and enforcement powers to the FIA, as well as delegated powers to the FIA and the FSC to publish and maintain an up-to-date list of designated persons and entities, which can be found on their respective websites. 

The Guidelines also detail the role of the SU as the point of contact in executing the powers and functions delegated to the AG as an authorised officer for the purposes of implementing, monitoring compliance with, and the detection of sanctions, by requesting information, inspecting records, and disclosing information as appropriate.

To assist entities in determining how they should report a potential sanctions breach, the Guidelines provide details of the format and method for submission of a report, the types of reporting forms to be utilised, as well as the type of information to be included in such submissions. 

To aid entities in identifying the circumstances under which to propose the designation of a person or entity, the Guidelines detail the process under the Counter-Terrorism Act, 2021 (CTA), which directs that such proposals, along with relevant supporting information are to be submitted to the Sanctions Coordinator in the SU. 

The Guidelines also capture key sanctions reporting obligations for Financial Institutions and Designated Non-Financial Businesses and Professions, which detail the prohibitions, offences and penalties for dealing with the assets, funds or economic resources of designated persons or entities, or on behalf of designated persons or entities under the CTA and the Proliferation Financing (Prohibition) Act, 2021. 

The Guidelines also identify the SU as the point of contact to be utilised to petition the Governor in relation to delisting requests under United Nations Sanctions Listings as well as delisting requests under the UK domestic sanctions regimes. 

The updated Virgin Islands Sanctions Guidelines are available here on the FSC's website and here on the FIA’s website. 

Questions concerning this Circular may be directed to [email protected].