Find out which BVI obligations apply to you

1. Is your register of beneficial owners accurate, up to date, and filed with your registered agent?

2. Have you prepared and filed your annual financial return with your registered agent for the last financial year?

3. Have you assessed and declared your economic substance classification for the last financial period?

4. Are your registers of directors, members, and charges up to date and filed where required?

5. Are your registered agent fees and annual government fees paid and is the company in good standing?

6. Are accounting records and underlying documentation kept and accessible for at least five years?

7. Do you screen owners, directors, and counterparties against UK and UN sanctions lists?

8. Do you have a privacy notice and procedures under the Data Protection Act, 2021?

9. Have you reviewed whether any of your activities require an FSC licence or DNFBP registration?

10. Do the directors meet at least annually and minute their oversight of compliance matters?

1. Is the organisation registered with the NPO Registration Board?

2. Have you filed the NPO annual return and financial statements for the last year?

3. Are the details of controllers, officers, and the registered address up to date with the Registrar?

4. Do you keep records showing the source and application of all funds for at least five years?

5. Do you conduct due diligence on major donors and on beneficiaries or partner organisations?

6. Do you screen donors, partners, and beneficiaries against UK and UN sanctions lists?

7. Do you have controls over funds sent to or received from overseas partners?

8. Have you assessed the terrorist-financing and misuse risk of your activities in the last 12 months?

9. Does the board or committee meet regularly and minute its oversight of finances and compliance?

10. Have officers and volunteers who handle funds received AML/CFT awareness training?

1. Was your AML/CFT/CPF policy manual updated and reviewed by the FSC in the last 12 months?

2. Did you record Annual (financial) Returns in the last 12 months from all business company customers?

3. Have you confirmed the annual economic substance status for all business company customers?

4. Do you maintain an updated Sanctions Register?

5. Have all members of staff and directors received annual AML/CFT/CPF training?

6. Do you have conflict of interest policies and procedures in place?

7. Is your risk matrix designed to assess the risk of doing business with non-face-to-face customers?

8. Does your AML/CFT/CPF manual contain internal reporting procedures for staff to communicate a suspicion of ML/TF/PF?

9. Did your last Compliance Officer Report include an indication of any breakdown in your internal controls structure?

10. Do you maintain an updated Institutional Risk Assessment tool?

1. Was your AML/CFT/CPF policy manual updated and reviewed by the FSC in the last 12 months?

2. Are all individuals, companies, and beneficial owners identified and verified before onboarding?

3. Do you maintain an updated Sanctions Register?

4. Have all members of staff and directors received annual AML/CFT/CPF training?

5. Are redemption and distribution payments made only to a bank account in the investor's own name, and are third-party payments into or out of the fund refused or subject to enhanced checks?

6. Is your risk matrix designed to assess the risk of doing business with non-face-to-face customers?

7. Does your AML/CFT/CPF manual contain internal reporting procedures for staff to communicate a suspicion of ML/TF/PF?

8. Where the fund's AML/CFT work is carried out by a fund administrator or other service provider, is there a written agreement setting out the relationship and associated obligations?

9. Do you maintain an updated Institutional Risk Assessment tool?

10. Are all transfers of fund interests to new investors blocked until due diligence on the new investor is complete?

1. Was your AML/CFT/CPF policy manual updated and reviewed in the last 12 months?

2. Are you effectively registered as a DNFBP and have you appointed an FIA-approved MLRO?

3. Have you put in place internal controls specific to your type of business activity?

4. Do you maintain an updated Sanctions Register?

5. Have all members of staff and directors received AML/CFT/CPF training in the last 12 months?

6. Do you apply a risk-based approach to your implementation of internal controls and customer management?

7. Do you conduct risk assessments in relation to all of your customers?

8. Does your AML/CFT/CPF manual contain internal reporting procedures for staff to report a suspicion of ML/TF/PF?

9. Do you have enhanced due diligence records for Politically Exposed Person (PEP) customers?

10. Do you maintain an updated Institutional Risk Assessment tool?