The Virgin Islands Government is pleased to share significant updates on the implementation of its National Action Plan. The Plan is aimed at enhancing the jurisdiction's compliance with international standards and was developed in response to the publication of the Fourth Round Caribbean Financial Action Task Force (CFATF) Mutual Evaluation Report (Report).

Premier, Dr. the Honourable Natalio Wheatley reinforced the commitment of the Virgin Islands Government, stating, "we are dedicated at the highest levels to remediating the Recommended Actions outlined in the Mutual Evaluation Report. Our government will continue to invest the required technical and financial resources to achieve these critical objectives."

Deputy Premier and Minister for Financial Services, Labour and Trade, Honourable Lorna Smith, OBE, affirmed the collaborative efforts of the Government, competent authorities, law enforcement agencies and the private sector, noting that, "identifying and combating financial crime is a cause we all recognise as vital. Together, we will ensure that the right mechanisms are in place to do so effectively."

Key progress made under the National Action Plan includes:

• The approval of an updated National AML/CFT/CPF Policy and Strategy by the National Anti-Money Laundering Coordinating Council and Cabinet, published on 30 September 2024.
• The establishment of the AML/CFT National Coordination Unit in the Attorney General’s Chambers, headed by a National Coordinator.
• The establishment of the Sanctions Unit, headed by a Sanctions Coordinator, in the Attorney General’s Chambers.
• The launch of the outreach series Collaboration and Commitment: Advancing Financial Services in June 2024, in partnership with key competent authorities and private sector associations. A second in-person event followed on 3^rd October 2024.  Both sessions, targeting supervised entities in the Virgin Islands, collectively addressed key cross cutting issues within the Report including beneficial ownership obligations, sanctions and risk.
• The publication of a comprehensive risk assessment of the non-profit organisations (NPO) sector to identify potential risks associated with terrorist financing.
• The formation of two working groups tasked with:
  
  • analysing the risks posed by legal persons and legal arrangements, with a draft risk assessment to be delivered during fourth quarter 2024.
  • conducting an enhanced targeted risk assessment on terrorist financing to identify and address any vulnerabilities, also due to be delivered during fourth quarter 2024.
• The passage of key legislative updates to ensure alignment with international standards, including: 
  • BVI Business Companies (Amendment) Act, 2024 
  • Trustee (Amendment) Act, 2024 
  • Banks and Trust Companies (Amendment) Act, 2024 
  • Insolvency (Amendment) Act, 2024 
  • Insurance (Amendment) Act, 2024 
  • Proliferation Financing (Prohibition) (Amendment) Act, 2024
  • Anti-money Laundering (Amendment) Regulations, 2024
  • Anti-money Laundering and Terrorist Financing (Amendment) Code of Practice, 2024
  • Limited Partnership (Amendment) Act, 2024
  • Financial Services Commission (Amendment) Act, 2024
  • Securities and Investment Business (Amendment of Schedule 1) Order, 2024
• The revision of risk assessment methodologies by AML/CFT/CPF supervisory agencies to more accurately reflect the money laundering, terrorist financing, and proliferation financing risks of their regulated entities. Following this re-evaluation and re-rating of entities under the new frameworks, the agencies are now conducting inspections based on a risk-sensitive approach, with a particular focus on higher-risk sectors such as Trust and Corporate Service Providers (TCSPs), Investment Business (IB), Virtual Asset Service Providers (VASPs), legal practitioners, and real estate agents.
• The dissemination of guidance and the conducting of focused outreach by AML/CFT/CPF supervisory agencies on critical areas, including the Virgin Islands' 2022 Money Laundering Risk Assessment, targeted financial sanctions, beneficial ownership and control, institutional risk assessments, the VASP travel rule, third-party introductions, Suspicious Activity Reporting (SAR) and risks related to money laundering, terrorist financing, and proliferation financing in the IB sector.
• The delivery of comprehensive training sessions for law enforcement agencies and members of the Judiciary and prosecutors to enhance their capabilities and effectiveness in tackling financial crime and implementing AML/CFT/CPF measures.
• The development of a public awareness campaign, to be launched during fourth quarter 2024, aimed at educating Virgin Islands residents and persons operating in the Virgin Islands, on relevant AML/CFT/CPF matters including the importance of complying with ‘know your customer’ requirements.

To bolster the Territory’s efforts, the Virgin Islands Government has engaged additional support from consulting firms Kroll and Claritas and is applying this expertise towards the successful outcome of the National Action Plan.

Kroll is a global leader in financial intelligence, assisting governments in strengthening their frameworks against money laundering and financing of terrorism. Its expert team, led by David Lewis, Managing Director & Global Head of AML Advisory, is focusing on financial intelligence and supporting law enforcement agencies with investigation, prosecution and confiscation matters.

The Claritas team, represented by founders Elisabeth Lees and Justine Plenkiewicz, brings extensive experience and expertise in regulatory compliance, and has provided advice to governments at all stages, from evaluation preparation through to procedures and reviews to enhance their compliance with international standards relating to financial crime and the regulation of financial services. Claritas is collaborating directly with Attorney General Honourable Dawn J. Smith, and the National Coordination Unit to advance the National Action Plan.

“We have assembled a strong team”, said Attorney General Honourable Dawn J. Smith. She emphasised that “it is imperative that the Virgin Islands Government plays its part in global efforts to combat financial crime. I am pleased that we are taking tangible steps to further strengthen our robust legislative framework, grow our law enforcement resources and capabilities, and continue to serve as a leading, international financial services jurisdiction.”

The Virgin Islands Government is committed to transparency and will continue to keep the public informed on progress made. Together, we will work to uphold the integrity of our financial system and ensure a secure business environment for all.