Following the addition of the British Virgin Islands (“BVI“) to the Financial Action Task Force (“FATF“) ‘grey-list’ of jurisdictions under increased monitoring for AML purposes in June 2025 and its consequential addition to the European Union (“EU“) list of high‑risk third countries for anti‑money laundering and counter‑terrorist financing (the “EU AML List“) at the end of 2025, BVI has already made considerable progress in seeking its swift removal from these lists with the Caribbean FATF rating BVI as compliant or largely compliant with all 40 of FATF’s Recommendations for technical compliance in October 2025.
In the interim, our client update considers the impact of BVI’s listing on the EU AML List, in particular for BVI funds being marketed into the EU under the EU Alternative Investment Fund Managers Directive. It also considers the limited practical consequences for clients using BVI vehicles generally of BVI being on the EU AML List and the FATF Monitoring List.
