Caribbean Regulatory Update – Q1 2026
Quarterly Update
Quarterly Update
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.
Contact
Alex Last
Craig Luton
Ian Montgomery
James Broad
Sara Galletly
This update is only intended to give a summary and general overview of the subject matter. It is not intended to be comprehensive and does not constitute, and should not be taken to be, legal advice. If you would like legal advice or further information on any issue raised by this update, please get in touch with one of your usual contacts. You can find out more about us and access our legal and regulatory notices at mourant.com. © 2026 MOURANT ALL RIGHTS RESERVED
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