As regulatory oversight intensifies, service providers must remain vigilant in their customer due diligence (CDD) processes to ensure compliance with evolving inspection standards. The recently announced 2024/25 Inspection Plan by the BVI Financial Services Commission (FSC) reinforces the necessity for robust CDD, ongoing due diligence (DD), and enhanced due diligence (EDD), with a particular emphasis on legal structures where beneficial ownership and control may not be immediately transparent or where the ownership structure seems complex.
Given this increased scrutiny, service providers must take proactive steps to ensure their Know Your Client (KYC) procedures align with regulatory expectations and the relevant frameworks.
Crucially, clear and comprehensive ownership charts—properly certified or signed by a senior official—can significantly streamline compliance requirements. Where beneficial ownership and control are clearly established within these documents, the need for registers of members (ROMs) at each layer may be minimised. However, where complexity obscures ownership and control, additional corporate documentation may still be required to ensure regulatory clarity. Providing transparent and well-structured ownership charts is now more important than ever, as they can prevent further document requests and facilitate a smoother compliance process.
With the BVI FSC’s upcoming inspections placing increased emphasis on due diligence, verification of legal structures, and risk assessments, service providers must ensure they are well-prepared to meet KYC requirements.
How does this affect our clients
At Marbury, our compliance team is committed to ensuring that our clients meet regulatory expectations efficiently. By providing clear, comprehensive, and properly authorised structure charts that clarify beneficial ownership, clients can significantly reduce the need for additional document requests and follow-up inquiries from regulatory bodies. This proactive approach not only streamlines compliance but also minimises potential delays particularly in communications and document provision from the Registry as well as disruptions in the future. Our Know Your Client requests are designed to protect clients from intensified scrutiny during inspections—ensuring compliance today to prevent complications tomorrow.
As always, we appreciate your assistance with these exercises to ensure all relevant documentation surrounding the company is up to date and valid. Should you have any queries about the compliance status of your entity, KYC requirements or the general ongoing obligations, please reach out to your usual Marbury relationship manager or info@marburys.com.
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