This paper explores the actions that should be considered following the latest grey-listing of the British Virgin Islands (BVI) and Bolivia.
BVI and Bolivia have been 'grey-listed' by the Financial Action Task Force (FATF) as of 13 June 2025. Countries on the FATF grey list have been identified as having strategic deficiencies in their anti-money laundering, terrorist financing, and proliferation financing regimes and they have been given a warning to address those deficiencies. BVI and Bolivia have formally committed to resolving these deficiencies quickly, within agreed timeframes, during which time they will be subject to increased monitoring.
In relation to BVI, CFATF’s 2024 mutual evaluation report highlighted strategic deficiencies in its AML/CFT/CFP regime, including gaps in its rules on identifying corporate beneficial owners. A follow up review conducted by the FATF highlighted comparable deficiencies in Bolivia. This may put businesses with connections to BVI and Bolivia under more regulatory scrutiny, as regulators (BMA, GFSC, JFSC and IOMFSA) will expect the implementation of more stringent AML/CFT/CFP compliance measures to mitigate the risks associated with grey listing. Furthermore, the grey listing may result in higher compliance costs and increased due diligence requirements for businesses.
As a trigger event, regulated businesses in Bermuda should conduct an impact assessment to determine any potential consequences or actions that may be required as a result. In anticipation of potential regulatory requests, businesses with ties to BVI and Bolivia may wish to consider preparing a proposed remediation plan, including indicative timelines for completion.
Croatia, Mali and the United Republic of Tanzania have been removed from the list. The countries had committed to a comprehensive action plan aimed at strengthening its AML/CFT/CFP framework. The three jurisdictions had successful on-site visits demonstrating progress in addressing the strategic deficiencies.
As a result, we would expect regulated businesses to:
- Formally document their impact assessment across their client book, even if the conclusion is that no exposure to BVI and Bolivia exists.
- Update their AML/CFT/CFP business risk assessment as needed, as well as relevant policies and procedures, such as controls on business acceptance and ongoing monitoring. This also includes recalibrating the configuration of AML software solutions.
- Identify existing customers with ties to BVI and Bolivia, including the source of funds and/or wealth of the customer, as well as associated parties, incoming and outgoing funds.
- Consider enhancing their due diligence procedures for BVI and Bolivia customers and/or counterparties, including enhanced customer due diligence measures and ongoing monitoring of transactions.
- Consider reviewing existing introducers/reliance arrangements involving entities in the BVI and Bolivia.
- Consider reviewing any contracts with BVI and Bolivian third parties to ensure that they include appropriate AML/CFT/CFP clauses, such as warranties and representations regarding compliance with AML/CFT/CFP laws.
- Consider alternative transaction routes, such as using correspondent banks that have strong AML/CFT compliance programs or engaging with BVI and Bolivian counterparties that have already implemented strong AML/CFT/CFP measures.
- Consider refreshing and/or rolling out AML/CTF/CFP training to their relevant staff to reflect these new provisions.
- Similarly, to consider the positive impact of Croatia’s, Mali’s and Tanzania’s removal from the Grey list.
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