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Changes to the money laundering regime of the BVI

The Anti-Money Laundering (Amendment) Regulations, 2015 and the Anti-Money Laundering and Terrorist Financing (Amendment) Code of Practice, 2015 have significantly reformed the BVI's money laundering regime.

The main objective of the changes has been to alter the introducer regime. There is now a requirement for those in the BVI subject to the regime, including registered agents, to collect much more information on the ownership of companies where they place reliance for customer due diligence ("CDD") purposes on a third party.

On which entities can reliance be placed

There has been some refinement in respect of which entities can be relied upon, but generally reliance can still be placed on regulated persons and members of professional bodies subject to rules of conduct and regulation in relation to their CDD procedures.

Information to be supplied by the introducer

The introducer must supply certain information to the registered agent about the BVI company but this does not need to be supported by documentary evidence. The introducer must supply information in relation to: the identity of its client using reliable, independent documents, data or information; the identity of any beneficial owner of the company; understand, where the client is a body corporate, the ownership and control structure of the body corporate; and the purpose and intended nature of the business relationship.

Written agreement

New terms must be put in place between the registered agent and the introducer. There are numerous provisions which must be included in this agreement such as: production of the CDD within a certain time scale; confirmation that the introducer has CDD measures in place and that reliance may be placed upon it; that local laws of the introducer do not prevent it from sending CDD to the registered agent; that the introducer agrees to sample testing; and provisions relating to the termination of the introducer's relationship with its own client.

Testing of the relationship

The relationship with the introducer must be tested by carrying out a periodic review, at least once every three years, of the introducer.

Transitional provisions

Essentially, these new provisions relating to introduced business must be complied with by a registered agent by 31 December 2016, and all introducers must have supplied the required information by this date.

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The information provided in this publication are put forward for further consideration only and are not intended to be acted upon without independent professional advice. Neither Jordans Trust Company Limited nor its associated group companies , nor any employees or directors of these companies can accept any responsibility or liability for any loss occasioned to any person no matter howsoever caused or arising as a result of or in consequence of action taken or not taken in reliance on the contents of this publication.

 Philip Jacques

Philip Jacques

Senior Legal Advisor 
T: +44 (0)117 918 1381

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