On 24 December 2024, the BVI published General Licence No. 8 (2024), allowing payments for reasonable professional legal fees and expenses related to designated persons under the Russia and Belarus sanctions regimes. This new licence, valid for six months, replaces earlier licences No. 3, No. 5 and No. 6, with important updates to fee caps and reporting requirements.
Key updates
Increased fee caps
- Legal fees: Up to US$2,400,000
- Expenses: 10 per cent of legal fees (capped at US$240,000)
Caps now apply per legal practitioner rather than per designated person across all legal matters.
Reporting obligations
- Notification: Inform the Attorney General before engaging in activities covered by the licence.
- Reporting: Submit a report to the Virgin Islands Sanctions Unit within seven days of any payment, using forms available on the BVI Financial Services Commission website. Email submissions are preferred at sanctions@gov.vg.
- Record keeping: Maintain records for six years.
Legal practitioners must carefully review the licence terms before use to ensure compliance.
Licence No. 8 of 2024 can be found here and BVI's General Licences page can be accessed here.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
