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  • Elizabeth A. McMorrow

Is BVI Ramping up for FATCA & CRS Examinations?

This week the British Virgin Islands (BVI) International Tax Authority (ITA) demonstrated its commitment to FATCA and CRS examinations by posting open positions with significant compliance responsibilities.

Head of Compliance Unit

The position includes a number of duties including developing and directing “an annual strategy and plan for compliance examinations/inspections in consultation with the Director to ensure adequate coverage of relevant Financial Institutions and to meet international standards.”

Part of the strategy requires that the Head develop compliance examination procedures manual(s) and co-ordinate examinations according to established processes or procedures.

Senior Compliance Examiner

Once hired, the Senior Compliance Examiner will be preparing examination programs related to CRS and FATCA.

Legal Counsel

As part of the new Legal Counsel’s representation of the ITA, she will serve as ITA trial counsel including the preparation of draft charges and cases. The Legal Counsel will prepare matters for prosecution and as part of that process communicate with the Police Department and the Director for Public Prosecutions.

BVI Cabinet Meeting

The ITA’s postings are consistent with the BVI Cabinet’s efforts “to place the jurisdiction in the best position to attain favourable ratings in the upcoming Group of International Financial Centre Supervisors assessment. . . .” (BVI Cabinet’s November 7, 2019 session).

The GIFCS is an association of the relevant authorities in jurisdictions identified as “offshore finance centers.” The GIFCS aims to cooperate with relevant international organizations in setting and promoting the implementation of international standards for cross-border banking supervision, and for combating money laundering and terrorist financing, to encourage members to apply high standards of supervision based on internationally accepted principles, to conduct mutual evaluations, to participate in the work of the Financial Action Task Force (FATF) and other international organizations, to improve international standards on combating money laundering and financing of terrorism, to continue work on implementation of FATF Recommendations and other relevant international standards.

Prepare for Examinations

Earlier this year, the European Union moved the BVI from the black list to the grey list. However, the EU warned the grey list jurisdictions that they needed to continue the positive steps already taken to comply with EU listing requirements. The EU’s expectation is that the work be completed by the end of 2019 to avoid being blacklisted in 2020.

Given the EU’s expectations and the United Kingdom’s continuing pressure on the BVI and other Crown Dependencies and Overseas Territories, it is likely that the BVI will try to make a public show of transparency compliance.

Based on the current position openings, the public show is likely to include FATCA and CRS examinations.

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