Financial Crime World

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Money Laundering Risk Assessment for British Virgin Islands (BVI)

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This comprehensive report on money laundering risk assessment for BVI was conducted by the BVI Financial Services Commission’s Anti-Money Laundering (AML) Unit. Below are key findings and expectations from the report.

Key Findings

  • Legal Persons: Legal persons, especially Business Companies Limited and Partnerships, are at high risk of being used for money laundering due to their complexity and ability to conceal ownership.
  • Legal Arrangements: Trusts are not commonly reported as suspicious activities but may be used by high-risk customers to distance themselves from illicit gains.
  • Gaming and Betting: The BVI is covered by the Gaming Control Act (GBCA), which prohibits gambling activities, but foreign lottery tickets are sold in the VI, and intelligence suggests that “keeping numbers” is being used as a money laundering method.
  • Medicinal Marijuana: The legalization of medical cannabis has raised concerns about compliance with international regulations.
  • Emerging Products and Technologies: Decentralized Financial Products (DeFi) facilitate transfer of funds but are at high risk due to lack of regulation, and the BVI’s ability to identify and prevent unauthorized activity is a concern.

Expectations

  1. Regulated Sectors: Review and adjust policies, procedures, and internal controls based on the report’s findings and legislative changes.
  2. Enhanced Monitoring: Demonstrate understanding of clients’ behavior and potential areas of concern, and make adjustments to client monitoring levels as needed.
  3. Institutional Risk Assessments: Implement institutional risk assessment frameworks, amend Section 11 of the AMLTFCOP, and ensure timely and accurate submission of statistical returns.
  4. Understanding ML Risks: Identify main money laundering risks within each sector, know how business, products, and services can be used to facilitate ML, and demonstrate effective implementation of mitigating measures.

Where to Find the Report

The report is available on the BVI Financial Services Commission’s website at bvifsc.vg/risk-assessments.