The BVI Association of Compliance Officers and Practitioners hosted a well-timed Masterclass on Tuesday, October 8, 2019, with focus on Sanctions and Suspicious Activity Reporting. 82 participants from the financial services industry were in attendance.
Presentations were delivered by representatives from the BVI competent authorities starting with Mr. Kenneth Baker, Deputy Managing Director – Regulation, of the Financial Services Commission (“FSC”). Mr. Baker delivered a pointed presentation highlighting recent changes in US Legislation which seek to expand the reach of US -imposed sanctions to non-US Financial Institutions. This becomes particularly relevant in the context of conducting financial transactions which must, of necessity, be cleared through US banks. The audience was encouraged to consider their screening mechanisms and whether they were adequate as tools for forestalling and preventing money-laundering and connected crimes.
This was followed by a presentation from Senior Analyst Mr. Westmore Jeffers of the BVI Financial Investigation Agency (FIA) on effective filing of Suspicious Activity Reports (“SARs”).
As part of a spirited question–and-answer session, Acting Interim Director Dwyane Thomas referenced the recently issued Guidance Notes on Suspicious Transaction and Suspicious Activity Reports, which took effect on October 1st, 2019. He went on to assure the audience that a new SAR form has been drafted and will be issued once the approval process is complete. The expectation is that this recalibrated form, together with the new Guidance Notes, will help to improve the quality of SARs filed and ultimately enhance their value as part of the investigative process.
Completing the sanctions portion of the Agenda was a presentation by Ms. Maria Mays, Head of Policy in the Governor’s office, who is charged, alongside representatives from the relevant BVI competent authorities, with assessing and determining applications for a licence to conduct business with a sanctioned / designated entity or individual. This presentation outlined the steps to be followed by industry practitioners who find themselves in such a position, subject to any changes which may occur as a result of the imminent Brexit.
In recognition of the FSC’s recently appointed oversight of compliance manuals for all Licensees under their remit, the ACO invited the FSC to also present on their expectations for compliance manuals and offer any guidance for improvement. This presentation was delivered by Ms. Helen Marquis.
The BVI ACO would like to expressly thank all Competent Authorities and their representatives who presented, as well as to our compliance colleagues who attended.
The presentations and issued guidance can be accessed via our website: www.bviaco.com
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