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Key takeaways
- On 20 November 2025, the VISU published a notice requiring all BVI entities which hold or control funds or economic resources controlled, held or owned by a Designated Person to file a new annual report by 30 November 2025.
- BVI entities must use the template annual reporting form provided by the VISU. Details of the frozen assets must reflect the position as at 30 September 2025.
- This new annual reporting requirement is in addition to existing obligations to report frozen assets to the VISU. Annual frozen asset reports must now be filed each year.
Frozen asset reporting: New requirement
The UK Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024 amended the sanctions regimes to introduce a new reporting obligation that applies to all persons that hold or control funds or economic resources controlled, held or owned by a person designated under UK sanctions (a Designated Person).
On 20 November 2025, the Virgin Islands Sanctions Unit (the VISU) published a notice in relation to frozen asset reporting clarifying the extension of this frozen asset reporting requirement to the British Virgin Islands (BVI). The notice is available here.
What does your entity need to do under the existing sanctions regimes?
Each BVI entity should:
- consider whether it maintains any accounts or holds any funds or economic resources for persons listed on the HM Treasury's Consolidated List of Asset Freeze Targets or any entities owned or controlled by such persons;
- freeze such funds or economic resources, including any accounts;
- refrain from 'dealing' (as broadly defined) with the funds or economic resources or making them available, whether directly or indirectly, to or for the benefit of a Designated Person or any entity owned or controlled by a Designated Person unless in receipt of a licence issued by the Governor or an exception applies;
- report any findings to the VISU via email at sanctions@gov.vg, along with any further information or other relevant matters that form the basis of such entity's knowledge or suspicion that the funds or economic resources are controlled, held or owned by a Designated Person; and
- submit any information regarding the frozen funds or economic resources belonging to Designated Persons that the VISU may request.
What does your entity need to do under the new frozen asset reporting requirement?
If a BVI entity holds or controls any funds or economic resources that are controlled, held or owned by a Designated Person, it must now provide an annual frozen asset report to the VISU with details of such assets in addition to the existing requirements outlined above. If your entity has, or should have, reported frozen assets to the VISU in a Compliance Reporting Form, it will likely also now have to file annual reports.
There is no need for an entity which does not hold or control funds or economic resources, controlled, held or owned by a Designated Person to provide a nil return to the VISU. However, if your entity has previously submitted a report of frozen assets that it holds or controls, and it no longer holds or controls those assets, a nil return will need to be submitted.
The annual frozen asset report needs to include details of all funds or economic resources frozen under the UK sanctions regimes, regardless of whether the BVI entity holds or controls them in the BVI or overseas. Assets frozen solely in response to the financial sanctions regimes of other jurisdictions do not need to be reported to the VISU.
What is the timing?
If required, your entity must file a report to the VISU no later than Sunday 30 November 2025.
Your entity should report the nature and amount or quantity of the frozen assets as at Tuesday 30 September 2025. If it is holding securities, shares or other debt or payment instruments as frozen assets, the report will need to include the USD value of such assets as at 30 September 2025.
What should entities do next?
Identify all the frozen assets the entity currently holds or controls and complete the template form.
The template form is available here and the required datapoints are set out below.
Datapoints to be reported:
- Reporting Entity;
- Type of Reporting Entity;
- Address of Reporting Entity;
- Name of Contact Person;
- Job Title;
- Contact Number;
- Email Address;
- Date of Report;
- Are you submitting this report on behalf of a third party? (If so, Name of Third Party Entity, Type of Entity (Third Party), Third Party Contact Person and Third Party Email Address must also be provided);
- BVI Fund / Entity;
- A/C Name;
- Type of Asset;
- Asset Freeze Target;
- OFSI Group ID;
- UK Sanctions List Unique ID;
- Sanctions Regime;
- Country funds held in;
- A/C Holding Institution / Firm;
- A/C Number;
- Sort Code;
- Type of Asset;
- Additional Institutions;
- Currency;
- Credit Balance / Asset Value in original currency (if applicable);
- Credit Balance / Asset Value in USD (if applicable);
- Debit Balance / Asset Value in original currency (if applicable);
- Debit Balance / Asset Value in USD (if applicable);
- Notes; and
- Date A/C opened.
If you have any questions, Walkers has a global team of dedicated regulatory lawyers who can advise your entities on the new reporting requirements. We have extensive experience of advising on financial sanctions compliance.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
