The BVI Financial Services Commission (FSC) has expanded its AML/CFT/CPF guidance framework in 2025 with two new guidance notes. The first covers Enhanced Customer Due Diligence (ECDD) requirements. The second addresses AML/CFT and Counter Proliferation Financing (CPF) obligations specifically for investment business licensees. Both sit alongside the existing AML Code of Practice and add specificity that was previously absent from the formal guidance framework.
The ECDD Guidance Note
The ECDD guidance note sets out when and how Enhanced Due Diligence must be applied beyond standard Customer Due Diligence. It introduces clearer criteria for triggering EDD, documented requirements for the enhanced information that must be obtained, and guidance on how EDD should be applied to high-risk client categories including Politically Exposed Persons and complex ownership structures. For entities that have been applying EDD based on internal policies alone, this guidance note creates a formal external standard against which the FSC can assess the adequacy of EDD procedures.
The AML/CFT/CPF Guidance for Investment Business
The second guidance note addresses AML/CFT/CPF obligations specifically for investment business licensees, covering the interaction between investment service delivery and AML/CFT controls. Counter Proliferation Financing is the newer component — CPF obligations require entities to screen for, and report on, transactions that may support the financing of proliferation of weapons of mass destruction. The guidance note explains how CPF screening integrates with existing AML/CFT controls and what documentation is required to demonstrate compliance.
The Inspection Risk
The FSC's compliance inspection programme is currently active and targeting investment business licensees, TCSPs, and VASPs. The publication of these guidance notes creates a new benchmark: inspectors can now assess whether an entity's ECDD triggers, documentation standards, and CPF procedures align with published FSC guidance. Non-alignment with formal guidance carries a higher inspection risk than a gap identified in the absence of such guidance.
What To Do Now
Download and review both guidance notes from the FSC's AML/CFT guidance page. Conduct a gap analysis of your current AML/CFT policies against the ECDD requirements, particularly around EDD trigger criteria and documentation standards. Ensure CPF obligations are incorporated into AML/CFT policy for investment business activities. Update staff training to include the new guidance note content before your next AML/CFT training cycle.