Industry Circular 9: FATF AML/CFT Compliance Due Diligence - October 2025
Summary
The British Virgin Islands Financial Services Commission issued Industry Circular 9 (2026) advising that FATF issued its October 2025 public statements identifying jurisdictions with strategic AML/CFT deficiencies. The Commission directs all persons subject to the Anti-Money Laundering Regulations, 2008 and the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008 to apply appropriate due diligence measures when dealing with customers or transactions connected to FATF-identified jurisdictions. For jurisdictions under increased monitoring, standard enhanced CDD applies; for high-risk jurisdictions subject to a FATF call for action, enhanced CDD and countermeasures are required.
All BVI-regulated entities should cross-reference their existing customer and counterparty databases against the current FATF public statements to identify any exposure to listed jurisdictions. For new customer onboarding and periodic reviews involving FATF-identified jurisdictions, firms should document enhanced due diligence rationale and consider whether transaction monitoring thresholds need adjustment. The Commission has linked the specific October 2025 FATF statements on its website—compliance teams should retrieve and file the relevant lists for audit purposes.
What changed
The BVI FSC issued Industry Circular 9 (2026) transmitting the FATF October 2025 Public Statements to all regulated entities under the Anti-Money Laundering Regulations, 2008 and Anti-Money Laundering and Terrorist Financing Code of Practice, 2008. The circular advises on two tiers of FATF-identified jurisdictions: (1) jurisdictions under increased monitoring ('grey list') requiring enhanced customer due diligence, and (2) high-risk jurisdictions subject to a FATF call for action ('black list') requiring enhanced CDD plus countermeasures. The circular also requires ongoing transaction monitoring for changes warranting adjustments to due diligence measures.
Regulated entities in the British Virgin Islands—including trust companies, corporate service providers, and other financial services licensees—must review their AML frameworks against the FATF designations and update screening and monitoring procedures accordingly. Compliance teams should verify whether existing customer databases include beneficial owners or counterparties from FATF-identified jurisdictions and ensure transaction monitoring systems can flag relevant activity.
What to do next
- Apply appropriate due diligence measures when dealing with customers or handling transactions connected with any of the jurisdictions under increased monitoring by the FATF
- Apply enhanced customer due diligence and, where necessary, other countermeasures to protect the international financial system from risks emanating from identified high-risk jurisdictions subject to a call for action by the FATF
- Continually monitor transactions of clients based in or doing business with any of the jurisdictions identified in the FATF public statements for changes that may warrant a change in due diligence measures
Archived snapshot
Apr 20, 2026GovPing captured this document from the original source. If the source has since changed or been removed, this is the text as it existed at that time.
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Industry Circular 9 of 2026 - FATF Public Statement - October 2025
Wednesday, 25 March, 2026
FATF October 2025 Public Statements
The British Virgin Islands Financial Services Commission (the Commission) wishes to advise that on 24 October 2025, the Financial Action Task Force (FATF) issued its latest public statements identifying jurisdictions with strategic deficiencies in their anti-money laundering and counter financing of terrorism (AML/CFT) regimes.
The Commission asks that all persons who are required to comply with the requirements of the Anti-Money Laundering Regulations, 2008 and the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008, note the concerns expressed by the FATF with respect to the named jurisdictions and consider the associated money laundering, terrorist financing and/or proliferation financing risks.
The Commission further urges all persons to:
a) apply appropriate due diligence measures when dealing with customers or handling transactions connected with any of the jurisdictions under increased monitoring by the FATF;
b) apply enhanced customer due diligence and, where necessary, other countermeasures to protect the international financial system from risks emanating from identified high-risk jurisdictions subject to a call for action by the FATF; and
c) continually monitor transactions of clients based in or doing business with any of the jurisdictions identified in the FATF’s public statements for changes that may warrant a change in due diligence measures.
The latest FATF Public Statement notifications identifying the countries under increased monitoring and those subject to a call for action by the FATF can be found here on the Commission’s website.
notificationofpublicationoffatfpublicstatementsoctober2025.pdf Posting Date: Wednesday, 25 March, 2026 British Virgin Islands Financial Services Commission uses cookies to capture data, allowing us to improve our site experience for everyone. To learn about how we use cookies please visit our privacy policy
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