The BVI financial services industry reaffirmed its commitment to regulatory effectiveness and global cooperation at the BVI Finance Breakfast Forum, held on Tuesday, November 18th. The critical session brought together regulators, practitioners, and compliance professionals to focus on a vital theme: improving the quality and effectiveness of Suspicious Activity Reports (SARs) to generate actionable intelligence and strengthen the jurisdiction’s robust anti–financial crime framework.
The forum, aptly titled “How to Turn Your Suspicious Activity Reports into Game-Changing Intelligence,” was moderated by Elise Donovan, CEO of BVI Finance. It featured crucial insights from two senior regulatory experts:
- Mr. Glenford Malone, Deputy Managing Director, Regulation — BVI Financial Services Commission (FSC)
- Ms. Miglisa Cupid, Deputy Director, Analysis & Investigation Unit — Financial Investigation Agency (FIA)
Their joint participation highlighted the necessary and continued collaboration between the BVI’s regulators and the private sector, which is a defining feature of the jurisdiction’s approach to maintaining high AML/CFT/CPF standards and meeting evolving international expectations.
Elevating the Quality of Suspicious Activity Reports
The core of the discussion centered on transforming SARs from simple compliance exercises into high-value intelligence inputs. Ms. Cupid outlined the FIA’s core quality criteria, providing a clear roadmap for improved filings. She stressed the absolute necessity of:
- Clear Identification: Accurately identifying the suspect or target, including relevant account and transaction details and unique identifiers (IDs, addresses, and, for VASPs, transaction hashes and wallet types).
- Accurate Rationale: Providing an accurate, comprehensive explanation of why the activity is suspicious, based on red flags, economic rationale, or behavioural anomalies, and not solely on complex structures or adverse media.
- Timeliness and Documentation: Ensuring swift reporting once suspicion is formed and including all relevant supporting documentation, along with evidence of internal investigations conducted by the Money Laundering Reporting Officer (MLRO).
Ms. Cupid also confirmed a major step forward in regulatory feedback: the FIA will introduce a formal SAR feedback process to the industry, scheduled to begin in late 2025 and extend into early 2026.
Strengthening Internal AML Frameworks
Mr. Malone underscored that the integrity of the SAR regime is directly linked to the strength of internal anti-money laundering (AML) frameworks. He reminded attendees that effective reporting is impossible without thorough client knowledge, stating, “If you don’t properly know and monitor your client, you can’t know what’s suspicious, and if you can’t identify unusual activity, you can’t identify suspicion.”
He encouraged firms to rigorously examine their monitoring frequency, risk scoring methodologies which must include threats, vulnerabilities and risk as identified in VI’s Risk Assessments related to ML, TF and PF, sanctions exposure management, and their overall ability to detect subtle changes in client behaviour, particularly within high-risk sectors such as Trust and Corporate Service Providers (TCSPs), Investment Business, and Virtual Asset Service Providers (VASPs). Both panelists reiterated that timeliness remains essential, noting that a SAR filed months or years after the fact has severely limited value for investigators.
Guidance on Complex Issues and Tipping Off
The experts also addressed several recurring industry challenges:
- Defensive SARs: The panelists advised that filings based purely on adverse media or incomplete Customer Due Diligence (CDD), without actual suspicion, are inappropriate. Ms. Cupid stated that such informational matters should instead be submitted via Information Reports.
- Responding to FIA Requests: To mitigate the risk of "tipping off" a client, the FIA confirmed that if a subject is a suspect or target, the Agency will not instruct a regulated agent (RA) or service provider to contact the client. Entities were strongly advised to ensure they maintain all required records internally to avoid any unnecessary client contact.
Commitment to Continued Engagement
Both the FSC and FIA confirmed that improving SAR quality is a top national priority, and the agencies will continue delivering coordinated industry outreach. Mr. Malone emphasised that the ultimate goal of this joint strategy is not simply enforcement, but achieving demonstrable effectiveness—leading to better investigations, prosecutions, confiscations, and outcomes in line with international standards like those set by the Financial Action Task Force (FATF).
The robust discussions at the Breakfast Forum reinforced the necessity of continued, sustained collaboration between the financial services sector and its regulators to ensure the British Virgin Islands remains a resilient, well-governed, and trusted jurisdiction on the global stage.
A full recording of the session is available here. If you have follow-up questions for the panelists, please submit them here.
About BVI Finance
BVI Finance is responsible for protecting and promoting the BVI’s financial services industry. The BVI is renowned as a leading international business and finance centre, offering a robust legal framework, a stable and business-friendly environment, and a strong reputation for regulatory compliance. With its strategic expertise in wealth management, corporate services, trusts, fund administration and digital assets, the BVI continues to attract global businesses, investors and financial professionals to use its products and services.
For further information please contact:
Shamahl A. Smith
Communications and Research Officer
ssmith@bvifinance.vg |Tel: 284-852-1957