The BVI Financial Services Commission (FSC) requires all licensees to submit annual AML/CFT returns under BVI's anti-money laundering and counter-financing of terrorism regulatory framework. FSC Industry Circular 5 of 2025 confirmed that the deadline for 2024 reporting period returns was March 31, 2025. Based on this established annual cycle, the 2025 reporting period return is expected to be due March 31, 2026.
What the Return Covers
The annual AML/CFT return allows the FSC to monitor the adequacy of each licensee's AML/CFT policies, procedures, and controls. It typically covers the reporting entity's client risk profile, CDD and EDD procedures, suspicious activity reporting volumes, staff training records, and AML/CFT governance arrangements. The return is a primary data source for the FSC's risk-based supervision programme.
The Context: Active FSC Compliance Inspections
The AML/CFT return deadline falls during the period when the FSC's compliance inspection programme is most active. The current programme targets Trust and Corporate Service Providers, Investment Businesses, and Virtual Asset Service Providers. Returns that are late or materially incomplete may trigger heightened supervisory attention or a compliance inspection. The FSC has made clear it treats AML/CFT governance as a baseline expectation across all licensees — not only those in higher-risk sectors.
What To Do Now
All entities holding a BVI FSC licence should confirm whether their 2025 AML/CFT return has been submitted or is in preparation. Ensure AML/CFT policies and procedures are current and documented, that staff training records cover the 2025 period, and that the return accurately reflects the entity's compliance posture. If you have not yet filed, prioritise doing so before March 31, 2026.