Update On The EU AML List – Limited Impact For The BVI

Key takeaways

• On 4 December 2025, the European Commission adopted the Delegated Regulation proposing to include the BVI in the EU AML List; the Delegated Regulation will not come into force until the twentieth day following its publication in the Official Journal of the European Union.

• No penalties or sanctions for BVI entities will arise from the BVI being added to the EU AML List.

• The Delegated Regulation acknowledges that the BVI has made significant progress on certain actions recommended in the MER and this progress is further evidenced by the CFATF recently upgrading the BVI's technical compliance rating so that the BVI is now rated as compliant or largely compliant with all of the FATF's 40 Recommendations.