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Research & Insight
Regulatory analysis and compliance guidance for BVI, Anguilla, and Curaçao — written for compliance leaders and regulated entities.
Jurisdiction
Compliance topic
11 articles
URGENT: BVI Penalty Moratorium Expires March 31 — BO and ROM Filing Deadline in Four Days
The BVI penalty moratorium on Beneficial Ownership and Register of Members filings expires on March 31, 2026. From April 1, any company that has not filed faces full enforcement — and filing links for pre-2025 companies expire at the same time. Public access to BO records also begins April 1.
Caribbean Guilder: Last Chance to Exchange ANG at Commercial Banks — Deadline March 31, 2026
The window for exchanging Netherlands Antillean Guilder (ANG) banknotes at commercial banks in Curaçao and Sint Maarten closes on March 31, 2026. After that date, ANG can only be exchanged directly at CBCS until 2055. Service providers should also update contracts and compliance documents that still reference ANG amounts.
BVI Annual AML/CFT Returns: March 31, 2026 Deadline for All FSC Licensees
All BVI FSC licensees are expected to submit their 2025 reporting period AML/CFT returns by March 31, 2026, following the annual cycle confirmed by FSC Industry Circular 5 of 2025. With compliance inspections active, late or incomplete returns carry heightened regulatory risk.
BVI FSC Publishes ECDD and AML/CFT/CPF Guidance Notes — What Regulated Entities Must Do
The BVI FSC has published two new guidance notes covering Enhanced Customer Due Diligence and AML/CFT/CPF obligations for investment business licensees. With compliance inspections underway, non-alignment with these guidance notes now carries a direct inspection risk.
Anguilla AML/CFT Regulations Updated — Enhanced BO Verification, PEP Screening, and SAR Requirements
Anguilla has updated its AML/CFT regulations following its CFATF mutual evaluation. The 2025 amendments introduce enhanced beneficial ownership verification, expanded PEP screening thresholds, new suspicious activity reporting categories, and stronger internal control requirements — all under active AFSC inspection focus.
Anguilla Beneficial Ownership Register: Updated AFSC Guidance Raises the Bar for Accuracy
The AFSC has issued updated guidance on Anguilla's beneficial ownership register requirements, clarifying qualifying thresholds, notification timelines, filing formats, and registered agent responsibilities. BO register accuracy is a stated focus of the current AFSC inspection programme.
AFSC Compliance Inspections Are Active — How to Prepare Your Documentation
The Anguilla Financial Services Commission is conducting compliance inspections through 2025 and into 2026, with corporate service providers and trust service providers as priority targets. Inspectors are examining AML/CFT controls, BO register accuracy, CDD records, staff training logs, and internal audit documentation.
CBCS Restructures Supervisory Framework — Faster Enforcement and No Tolerance for Late Filings
The Central Bank of Curaçao and Sint Maarten restructured its supervisory framework effective January 1, 2026, introducing risk-based supervision and significantly reducing tolerance for late regulatory submissions. Extension requests will only be granted in exceptional circumstances.
BVI Economic Substance Filings Migrate to VIRRGIN — BOSSs System Decommissioned
The BVI International Tax Authority has migrated all Economic Substance filing from the legacy BOSSs system to VIRRGIN, effective January 2, 2026. Registered agents lost BOSSs access on December 26, 2025. All ES filings must now be submitted exclusively through VIRRGIN.
Curaçao Introduces VASP Licensing Regime — Virtual Asset Activities Now Require CBCS Licence
Curaçao enacted its VASP Act on March 13, 2025, establishing a formal CBCS licensing framework for five categories of virtual asset activity. VASP operators now carry the same AML/CFT obligations as traditional financial institutions. Unlicensed virtual asset activity is no longer permitted.
Curaçao UBO Register Fully Enforced — Digital KvK Portal Live, July 2025 Deadline Passed
The Curaçao Chamber of Commerce launched a digital UBO registration portal in May 2025, and the July 1, 2025 registration deadline for all existing legal entities has passed. Administrative fines of up to XCG 25,000 apply to non-compliant entities. Ongoing obligations require UBO changes to be reported within two weeks.