The Virgin Islands Sanctions Unit ("VISU") has announced a mandatory frozen-assets reporting requirement for 2025. All persons who hold funds or economic resources that are "owned, held or controlled" by a designated person must submit a report to VISU by 30 November 2025 stating the value of those assets as at 30 September 2025.
This obligation stems from amendments to a wide set of UK financial services regulations made under the Sanctions and Anti-Money Laundering Act, 2018, which have been extended to the Virgin Islands through corresponding Orders in Council (the "Modified Sanctions Regulations").
Scope of the requirement
VISU requires any person holding such funds or economic resources to report them, regardless of sector or legal form. This will commonly include investment funds and managed accounts, administrators, custodians and depositories, trustees and corporate service providers, and structures holding crypto assets, where those assets are owned, held or controlled by a designated person.
Assets located outside the BVI must also be reported if they are subject to the Modified Sanctions Regulations. By contrast, accounts blocked solely under another national regime (such as OFAC-only blocks) are not required to be reported to VISU.
Reporting mechanics
Reports must be submitted using the prescribed templates available from the BVI Financial Services Commission and Financial Investigation Agency websites and emailed to sanctions@gov.vg.
Each report must include details of all frozen funds and economic resources, with values stated as at 30 September 2025. Where the assets are securities, shares or other debt or payment instruments (including those denominated in foreign currencies), the USD value must also be provided.
Nil returns are not required unless the filer has previously submitted a frozen-assets report and no longer holds or controls those assets.
Separately, all persons remain under an ongoing obligation to identify, freeze and report funds or economic resources of designated persons, including a requirement to report newly frozen assets without delay. Failure to comply with financial services legislation, or to seek to circumvent it, is an offence.
Implications for BVI funds and other entities
While VISU does not comment on governance or operational impact, the new reporting requirement has practical consequences for BVI structures:
- Sanctions governance. Funds, administrators, trustees and custodians will need to demonstrate that ownership, control and designation screening processes are robust and can support a valuation-date driven filing.
- Valuation alignment. The 30 September valuation date and 30 November deadline intersect with audit and year-end timelines. Entities should plan for reconciliations and NAV implications.
- Cross-border holdings. Structures with PRC, CIS, Middle East, African or digital-asset exposure may face complex ownership-and-control assessments, particularly where entities are not expressly named on consolidated lists but are indirectly controlled by designated persons.
- Responsibility and oversight. VISU recommends appointing a single responsible person for filings to avoid duplicate submissions. In practice, boards, general partners and trustees should ensure oversight and record-keeping are defensible and ensure there is a single person with authority to file.
