VISU sanctions reporting in BVI due 30 November

The Virgin Islands Sanctions Unit (VISU) published details on 20 November regarding a new annual sanctions reporting obligation for 2025 requiring a BVI person that holds funds or economic resources owned, held or controlled by a Designated Person (that is, an individual or entity sanctioned by the UK Government) to file a report with the VISU providing details of those frozen assets by Sunday 30 November 2025.

Key details of the new sanctions reporting obligation

The annual reporting obligation will be relevant to (among others) BVI funds holding underlying assets that are frozen either because the Designated Person owns those assets (for example by way of a legal or equitable interest in the assets), holds the assets (for example assets held on a settlement depository that is itself a Designated Person) or controls the assets, or because the investment fund itself is considered to be owned by a Designated Person (for example through majority ownership by a Designated Person). Impacted persons will need to report details of frozen assets by completing and fling either the relevant parts of the existing VISU Compliance Reporting Form (use Parts A and C (frozen assets) and Annex2 guidance) (CRF) or by using the dedicated Frozen Assets Reporting Template (Reporting Template) circulated by the VISU with the notice of the new obligation. Details of frozen assets and values should be as at 30 September 2025 and completed forms (whether using the CRF or Templete) must be filed with the VISU via email to sanctions@gov.vg by 30 November 2025.

Next steps

As the first reporting deadline is 30 November 2025, relevant entities should consider the VISU's published guidance and check if they are in scope of the reporting obligation as soon as possible. For assistance with assessing whether you are in scope of the requirements, please reach out to your usual Ogier contact or any of the key contacts below.

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

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