Anguilla has updated its Anti-Money Laundering and Countering the Financing of Terrorism regulations in 2025. The amendments implement action plan items identified following Anguilla's CFATF mutual evaluation — the Caribbean Financial Action Task Force's assessment of the jurisdiction's AML/CFT framework — and bring Anguilla's rules into closer alignment with current FATF Standards.
The Key Changes
The 2025 amendments introduce four substantive changes that affect all entities regulated by the Anguilla Financial Services Commission (AFSC).
Enhanced beneficial ownership verification requires reporting entities to apply more rigorous BO verification procedures when onboarding new clients and when changes to beneficial ownership occur. The standard for what constitutes adequate BO verification has been raised beyond what earlier regulations required.
Updated PEP screening thresholds expand the categories of Politically Exposed Persons that require Enhanced Due Diligence. The expanded categories reflect FATF guidance and may require entities to reclassify clients who were not previously subject to EDD under the prior PEP definitions.
Expanded suspicious activity reporting adds new categories of suspicious conduct that must be reported to the Financial Intelligence Unit. Entities should review their SAR trigger criteria against the new categories to ensure nothing reportable is missed.
Strengthened internal control requirements require regulated entities to demonstrate robust AML/CFT governance — including documented policies, independent audit functions, and staff training programmes — as a standing regulatory obligation, not only during inspections.
Who Is Affected
These changes affect all entities regulated by AFSC: corporate service providers, trust service providers, investment business licensees, registered agents, and any other AFSC licensee subject to AML/CFT obligations. Compliance with the updated regulations is a stated focus of AFSC's 2025-2026 inspection programme.
What To Do Now
Review and update your AML/CFT policies and procedures against the 2025 amendments. Update CDD and EDD procedures to reflect enhanced BO verification requirements. Review your PEP screening lists and thresholds and update your screening process if necessary. Check that your SAR reporting procedures cover the newly expanded categories. Ensure staff training is current and covers the 2025 changes.