BVI Update: New MLRO Requirements

On 15 October 2024, amendments to the Anti-Money Laundering Regulations (As Revised) ("AML Regulations"), previously published in the Gazette, came into force.

The changes include that money laundering reporting officers ("MLROs") will have to be approved by the Financial Services Commission ("Commission") / British Virgin Islands ("BVI") Financial Investigation Agency ("FIA") before they are appointed by a relevant person, i.e. a person / entity who is licensed or registered to carry on a relevant business in or from within the BVI, and the Commission / FIA may require the person to submit further documents or attend an interview / take a test as part of the process.

Existing MLROs will be 'grandfathered' under the amended AML Regulations, which set out that any person appointed as an MLRO before the amended AML Regulations came into effect shall continue to hold office as an MLRO as if their appointment was approved under the amended regulations. Under the