Compliance, AML/KYC & due diligence

What this covers

• We build AML/KYC procedures and a written compliance manual. That means a risk-based customer risk assessment, CDD and EDD workflows, PEP and sanctions screening, record-keeping and suspicious-activity reporting lines, all tailored to the entity's jurisdiction and regulator.
• We arrange the appointment of a compliance officer, or MLRO, and a deputy who meet local fit-and-proper standards. In the BVI, the MLRO must hold at least a diploma with three or more years' relevant post-qualification experience, and must be approved by the FSC/FIA before appointment. In Cayman, the requirement is a natural person at managerial level, plus a deputy.
• We run standard and enhanced due diligence. This covers identity checks, along with source-of-wealth and source-of-funds verification. Enhanced due diligence, or EDD, applies where a party is a politically exposed person, or connected to a FATF-listed or high-risk third country.
• We verify counterparties and backgrounds before any transaction goes ahead. That means corporate-registry and UBO checks, litigation and insolvency searches, and adverse-media and sanctions screening on principals and their advisers.
• We map the reporting perimeter across the family's entities. That means identifying which vehicle is a reporting financial institution, which is a passive NFE, and where controlling persons must be reported, so obligations are neither missed nor duplicated.
• We coordinate ongoing reporting to each regime's deadline. This covers FATCA (US accounts via Model 1 IGA), CRS and CRS 2.0, beneficial-ownership register filings, and, where still applicable, economic-substance returns.
• We scope exposure to the new crypto regimes. CARF and CRS 2.0 now capture wallets, exchanges and tokenised holdings, with first exchanges due in 2027, and we do this work before the first collection year closes.
• We hand regulated execution to appointed local counsel, MLROs and auditors. We remain the family's single coordinating point across jurisdictions.

Scope & conditions

CRS 2.0 (global)

The amended Common Reporting Standard applies from 1 January 2026, with first reporting in 2027. It now captures crypto-assets, specified e-money and CBDCs, and requires more granular data — each controlling person's role, joint-account details, and new-versus-pre-existing flags. As of 2026 — confirm your jurisdiction's filing date, often 31 May.

CARF (crypto)

Reporting crypto-asset service providers collect data from 1 January 2026. Around 52 jurisdictions — including the UK, Switzerland, the Cayman Islands and most of the EU — commit to first exchanges in 2027; the UAE, Hong Kong and Singapore in 2028; and the United States in 2029.

EU (AMLR / AMLA)

The EU AML Regulation (2024/1624) applies directly in all 27 member states from 10 July 2027. The beneficial-owner threshold becomes 25% or more (from 'more than 25%'), and AMLA in Frankfurt — operational since 1 July 2025 — begins direct supervision of roughly 40 selected high-risk entities from 1 January 2028. Confirm.

BVI (economic substance)

Nine relevant activities. The economic-substance report is due within six months of the financial period end — a 31 December 2025 period means a 30 June 2026 deadline — filed via the registered agent, now on the VIRGIN platform. Extensions are generally not available.

UAE (substance)

Standalone Economic Substance Regulations were withdrawn by Cabinet Decision No. 98 of 2024 for financial years ending after 31 December 2022 — no further ESR notifications or reports, and fines for those later years are being refunded. Substance is now tested inside the Corporate Tax regime (Federal Decree-Law No. 47 of 2022).

United States (FATCA & CTA)

FATCA reporting of US accounts continues via Model 1 IGAs; IRS Notice 2024-78 extends relief for missing US TINs on pre-existing accounts through calendar years 2025–2027. Under FinCEN's interim rule of 26 March 2025, US-formed companies and US persons are exempt from CTA beneficial-ownership reporting — only foreign-formed entities registered in a US state must file. A final rule is expected.

United Kingdom (overseas property)

Overseas entities buying, selling or transferring UK property must be on the Register of Overseas Entities and disclose beneficial owners (more than 25% of shares or votes, or control of the board), with an annual update statement. FATF grey-listed countries are 'high-risk third countries' under Regulation 33 of the MLR 2017, so EDD is legally required for relationships touching them.

How it works

• We work from documents. Certified identity, proof of address, ownership charts to the ultimate beneficial owners, and source-of-wealth evidence. Nothing is taken on assertion. Source of funds and substance are now verified, not assumed.
• The regulated roles are held by licensed local providers. We arrange and instruct the MLRO or compliance officer, counsel and auditors. The appointment, sign-off and filings are theirs, and they must meet each jurisdiction's fit-and-proper and approval requirements. In the BVI, for example, an MLRO needs prior FSC/FIA approval.
• Reporting runs to fixed deadlines. A BVI ES report is due six months after period end, and CRS and FATCA filings typically fall in the spring. This means we need lead time. Late or missing filings carry penalties in every regime.
• Enhanced due diligence is triggered by law where a party is a PEP or connected to a FATF-listed or high-risk third country. This adds documentation and time, and it cannot be waived to suit a timetable.
• Pricing for regulated work is quoted by the appointed providers to the agreed scope. We do not publish fixed fees. Any figure is confirmed in writing before you commit.