BVI Annual AML Training 2025/2026
Annual AML Training for the British Virgin Islands, updated for 2025/2026, hosted by Provenance Compliance
A Warm welcome
Contents
Part 1: The Basics of Money Laundering, Terrorist Financing and Other Terms
Money Laundering
The 3 Stages of Money Laundering
The Impacts of Money Laundering
Terrorist Financing
The Costs of Terrorist Financing
Proliferation Financing
The Costs of Proliferation Financing
Cryptocurrency Considerations
Part 2: Case Studies
TD Bank hit with $3 Billion AML Penalty
TD Bank Continued
ISIS-K (ISKP) and Cryptocurrency
ISIS-K (ISKP) Part 2
ISIS-K (ISKP) Part 3
ByBit Cryptocurrency Heist
ByBit Cryptocurrency Heist Part 2
Part 3: Legislative Framework And The Role of AML Officers And The Board
BVI, AML/CTF Legislative Regulatory Framework
BVI AML/CTF Legislative and Regulatory Framework
Regulatory Authorities
Codes and Guidelines
National Risk Assessment of Legal Persons and Legal Arrangements (NRA) Key Highlights (2025)
Institutional Risk Assessment (IRA)
Institutional Risk Assessment Risk Categories & Methodology
The Proceeds of Criminal Conduct Act:
Anti-Money Laundering Regulations (AML Regs)
AML & Terrorist Financing Code of Practice (AML Code)
Enforcement and Penalties – BVI AML/CFT/CPF Regime
The Roles in AML Compliance
Compliance Officer (CO) Duties and Responsibilities (BVI Regulatory Code, 2009)
Money Laundering Reporting Officer (‘MLRO’)
MLRO Appointment Approval Requirement AML Regulations, 2024 (Amendment)
Enhanced MLRO Notification and Compliance Requirements
Enforcement Actions and Compliance Trends
AML/CFT/CPF Policy and Strategy – BVI (2025-2027)
Part 4: International Standards
FATF grey listing of the BVI
Other International Standard Setters
Part 5: The Risk Based Approach & AML Programme
The Risk Based Approach (RBA)
AML Business Risk Assessment
AML/CFT/CPF Policy and Strategy – BVI (2025-2027)
Customer Due Diligence (CDD)
Identification vs Verification
The Timing of identification and verification
Electronic, Know Your Customer (E-KYC)
Control and Ownership
Beneficial Ownership Regime Changes
Source of FUnds vs Source of Wealth
Enhanced Due Diligence
High-Risk Scenarios requiring Enhanced Due Diligence
Politically Exposed Persons
Record Keeping Procedures
Geographic Risk
Employee Screening and Training
Part 6: Suspicious Transaction Reporting
Suspicious Activity Reporting (SAR)
Internal Procedures for SAR
Tipping Off Offence
Part 7: Transaction Monitoring And Ongoing Monitoring
Ongoing Monitoring and Cyclical Reviews
Transaction Monitoring (TM)
One-Off Transactions
Guidance on an Effective Approach to Ongoing Monitoring
Record Keeping
Subscriptions in Kind and Virtual Assets
Enhanced Due Diligence for Subscriptions in Kind Practical Guidance
Part 8: Targeted Financial Sanctions
Targeted Financial Sanctions (TFS)
Revised Sanctions Guidelines British Virgin Islands, 2025
Compliance with Targeted Financial Sanctions (TFS)
Risks for FSPs of Non-Compliance with TFS
Thank you
Annual AML Training