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All regulated persons need to file their respective prudential returns by 15 May 2021

Securities and Investment Business Act 2010 licensees will need to submit the Investment Business Annual Return and the Anti-Money Laundering / Countering the Financing of Terrorism (AML/CFT) Return by 15 May 2021.

Persons holding a Class I, II, III, IV, V trust licence, Restricted Class II and III trust licences under the Banks and Trust Companies Act 1990 (BTCA) as well as persons holding company management licences under the Company Management Act 1990 do not have to submit the Fiduciary Services Business Annual Return for the 2020 reporting year but they have to submit the AML/CFT Return for the year 2020 by 15 May 2021.

Insurance licensees, under the Insurance Act 2008 holding:

  • a Category C, D, E or F insurance licence will have to submit the Captive Insurance Business Annual Return together with the AML/CFT Return by 15 May 2021;

  • a Category A or B insurance license will have to submit the Domestic Insurance Business Annual Return together with the AML/CFT Returns by 15 May 2021;

  • an insurance intermediary licence (such as an insurance agent or insurance broker) will have to submit the Insurance Intermediary Annual Return together with the AML/CFT Return by 15 May 2021;

  • an insurance manager licence will have to submit the Insurance Manager Annual Return together with the AML/CFT Return by 15 May 2021.

Persons who hold a financing business licence or a money services business licence under the Financing and Money Services Act 2009 will have to submit the AML/CFT Return by 15 May 2021.

Insolvency practitioners who hold an insolvency practitioner's licence under the Insolvency Act 2003 will have to submit the AML/CFT Return by 15 May 2021.

Banks, whether holding a general or a restricted licence, under the BTCA will continue to file the prudential returns for banks on a quarterly basis within 15 days following the end of the relevant quarter to which the return relates in addition to the AML/CFT Return which is due by 15 May 2021.

A link to our previous note on the Harneys Regulatory Blog which contains the various prudential returns for each category of licensee along with the administrative penalties regime that applies can be accessed here.

The authorised representative can assist with submitting completed returns to the BVI Financial Services Commission. If any licensee would like assistance with that please contact BVIFundServices@harneys.com.

Key contacts

Aki Corsoni-Husain
Partner • Cyprus
+357 2584 4326
aki.corsoni-husain@harneys.com

Philip Graham
Partner • British Virgin Islands
+1 284 852 2551
philip.graham@harneys.com

Ayana Hull
Counsel • British Virgin Islands
+1 284 852 2553
ayana.hull@harneys.com

Mirza Manraj
Counsel • Hong Kong
+852 5806 7895
mirza.manraj@harneys.com

Kimberly Seagojo
Associate • British Virgin Islands
+1 284 852 2554
kimberly.seagojo@harneys.com

About Harneys  

We are a global offshore law firm with entrepreneurial thinking. Through our associated corporate and private wealth services business, Harneys Fiduciary, we offer corporate, trust and fiduciary services.

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