BVI SARs: BVI Finance Webinar on Improving the Quality of SARs Filings

The webinar included detailed insights from Mr. Glenford Malone, of the BVI Financial Services Commission and Ms. Miglisa Cupid of the BVI Financial Investigation Agency (FIA). Aimed at industry professionals making SARs filings in practice, the webinar focussed on transforming SARs from simple compliance exercises into high-value intelligence inputs, by clear identification of the suspect or target, accurate explanation of why the activity is suspicious, swift reporting once a suspicion is formed and including all relevant supporting documentation with the filing.

Mr Malone emphasised that the integrity of the SAR regime is directly linked to the strength of entities’ internal AML frameworks, for entities to be able to identify unusual activity and what may be suspicious, with effective reporting being impossible without thorough client knowledge.

The panellists also considered industry questions on:

• Defensive SARs: advising that filings based purely on adverse media or incomplete customer due diligence, without actual suspicion, are inappropriate. Such informational matters should instead be submitted via Information Reports.
• Responding to FIA Requests: To mitigate the risk of “tipping off” a client, the FIA confirmed that if a subject is a suspect or target, the FIA will not instruct a registered agent or service provider to contact the client. Entities were strongly advised to ensure they maintain all required records internally to avoid any unnecessary client contact.

The FIA is also planning to introduce a formal SAR feedback process to industry, in late 2025/early 2026.

A recording of the webinar is available from BVI Finance and follow up questions can also be submitted via BVI Finance using this form.

Maples Group has considerable experience advising entities on their AML compliance obligations. Please reach out if we can be of assistance.