BVI Regulatory Obligations And Filing Deadlines

AUDITED ACCOUNTS – 30 JUNE 2015

FUND ANNUAL RETURN – 30 JUNE 2015

US FATCA – 30 JUNE 2015

RECORD KEEPING – IMMEDIATE

TIGHTENING ATTITUDE OF THE COMMISSION TO LATE FILINGS

Over the last six months we have seen that the British Virgin Islands ("BVI") Financial Services Commission (the "Commission") has become increasingly strict with payment and filing deadline contraventions and we are expecting to see administrative penalties levied in particular in respect of late filings of accounts, failure to obtain the prior consent of the Commission (where required) and changes to functionaries.

As such, we recommend all regulated entities to review their procedures for identifying changes that require notifications to or approvals of the Commission and to undertake a review of their current status with the Commission, with a view to bringing all requisite filings up to date before 30 June 2015.