On 24 January 2025, the BVI Financial Services Commission (FSC) and the Financial Investigation Agency (FIA) issued new guidance to enhance how financial institutions (FIs) and designated non-financial businesses and professions (DNFBPs) monitor their customers.
The guidance, titled "An Effective Approach to Ongoing Monitoring," outlines steps to identify risks, unusual transactions and compliance breaches under the British Virgin Islands anti-money laundering, counter-terrorist financing, and counter-proliferation financing (AML/CFT/CPF) framework. It emphasises the importance of developing customer profiles, using due diligence to monitor changes in behaviour or risks, and implementing robust systems and oversight.
Key points include:
- Customer risk profiling: Creating baseline profiles through due diligence to identify risk factors like sanctioned individuals, high-risk industries, or politically exposed persons
- Transaction monitoring: Identifying patterns that signal suspicious activity or inconsistencies with customer profiles
- Third-party monitoring: Ensuring outsourced monitoring meets legal and regulatory standards
- Building a robust monitoring system: Integrate risk awareness, effective oversight, and staff training into business practices
BVI FSC CEO Kenneth Baker stressed the need for vigilance, stating, "Effective monitoring through reliable data, training, and robust systems is crucial to mitigating money laundering and terrorism financing risks." Similarly, BVI FIA Director Errol George highlighted the importance of tailored approaches to customer monitoring, urging businesses to assess whether high-risk relationships should continue.
The full guidance is available on the BVI FSC's website here and here and on the BVI FIA's website 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.
