Caribbean Regulatory Update – Q1 2026
08 January 2026
This Regulatory Update provides a snapshot of the key legal developments in the BVI and the Cayman Islands over the last quarter, including:
- amendments to the UK sanctions regime and the introduction of a new sanctions reporting obligation;
- details of the OECD's CRS 2.0 and Crypto Asset Reporting Framework and timing of implementation;
- beneficial ownership regime updates;
- new regulatory publications for virtual asset service providers; and
- details of filing dates and government fee increases.
See below for more details on the topics covered in this Update.
Key BVI Updates in Q1 2026
UK sanctions designations moving to a single list
UK sanctions extended to BVI and Cayman - Irregular migration and people trafficking
Introduction of new sanctions reporting obligation
BVI FSC Guidance on Terrorist Financing Red Flags
BVI FSC - Informational video highlighting risks associated with the misuse of BVI Business Companies
CRS 2.0 and CARF update
Amendment to BVI Financial Services Administrative Penalties Regulations
BVI FSC Circular - Extension of dates for filing fees
Guidance on filing of beneficial ownership information
BVI FSC Circular - Updated guidance on batch bulk filing template of beneficial ownership information
Economic substance filings – Transition to VIRRGIN
BVI FSC Industry Notice - Temporary access to VIRRGIN LITE for beneficial ownership filings
FATF rating progress
EU list of high-risk jurisdictions for AML/CFT
BVI FSC Industry Circular – Continuations out
Limited partnerships annual return
BVI FIA Notice - Annual returns for DNFBPs and NPOs
FAQs - Virtual Assets and VASP Regulation
BVI FSC Quarterly Newsletter Q4 2025
Q3 2025 FSC Statistical Bulletin
Mourant Guides and Updates
Mourant online AEOI compliance training
Key Cayman Updates in Q1 2026
UK sanctions designations moving to a single list
UK sanctions extended to Cayman - Irregular migration and people trafficking
Introduction of new sanctions reporting obligation
Further amendments proposed to the beneficial ownership regime
CIMA Notice - Updates to fund deregistration forms
CRS 2.0 and CARF Regulations in force
VASP Financial Returns Form
CIMA Strix XRBL User Guide
Country-by-Country Reporting on the DITC portal
CIMA Notice - Government fee increases
CIMA Notice – New prudential information survey for Registered Persons
Amendments to the Companies Act in force
Mourant Guides and Updates
Mourant online AML and AEOI compliance training
For additional information or for any questions, please reach out to your usual Mourant contact or one of the key contacts provided on this page.
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About Mourant
Mourant is a law firm-led, professional services business with over 60 years' experience in the financial services sector. We advise on the laws of the British Virgin Islands, the Cayman Islands, Guernsey, Jersey and Luxembourg and provide specialist entity management, governance, regulatory and consulting services.
