BVI VASP License Compliance Officer Services 

Compliance officer for BVI VASP license

When establishing a virtual asset service provider (VASP) in close compliance with UK regulatory framework, British Virgin Islands VASP license compliance officer services are paramount. A compliance officer is the first step in the BVI’s VASP provisions to ensure that business entities can meet strict anti-money laundering (AML), counter-terrorism financing, and governing agency standards per local jurisdiction regulations and international compliance guidance including that of the Financial Action Task Force (FATF). VASP compliance in the BVI just became significantly harder since the BVI AML Regulations have changed to require a detailed risk-based AML and compliance program, enhanced due diligence, financial, and compliance reporting to the BVI Financial Services Commission (BVI FSC), priority compliance with the possibility of penalties exceeding US$150,000 for non-compliance. 

• According to the BVI FSC, total companies registered in the BVI at mid-year 2024 exceeded 358,592 after new registrations grew over the previous year by greater than 50%. In addition, approximately 8.3% of the companies registered in the BVI were new company registrations in a 12-month period. This speaks to a competitive and active compliance arena. The shortage of experienced compliance officers is underscored by recent statistics from the FSC. A high number of appointments is a strong indication of the quality of professional advice a potential client should seek to register company in BVI, particularly under the latest provisions of the VASP Act. 

• Tetra Consultants provides BVI VASP license compliance officer services to assist clients at each step of the regulatory journey including finding suitably qualified compliance professionals, developing risk management frameworks, and ensuring continued alignment with the most up-to-date BVI FSC standards. With deep experience in the BVI regulatory framework, we are in unique to provide pragmatic solutions and flexible collaboration that allows our clients to secure and maintain BVI VASP license in accordance with optimal compliance values, which is of the utmost importance in the quickly changing virtual asset environment.  

Benefits of appointing BVI VASP license compliance officer services

Ensures regulatory compliance 

• Your compliance officer is accountable for ensuring that the VASP complies with the regulatory requirements for the British Virginia Islands under the VASP Act, including the financial obligations to comply with anti-money laundering (AML) and counter-terrorism measures (CTF) obligations to ease the risk of sanctions or, worse, a loss of the VASP’s license.  

Primary corresponding officer for regulators 

• They will be your VASP company’s primary corresponding officer for your VASP to full regulatory relations with the BVI Financial Services Commission (FSC), ensuring that your compliance officer effectively discharges the VASP’s obligations for reporting, audits, and inspections or just inquiries in a timely manner to maintain a good relationship with, possibly, your most important stakeholders – the regulators. 

Risk mitigation 

• If your compliance offer is a qualified person, they will establish and maintain a full compliance manual and internal controls etc. It will now minimize if not eliminate operating, financial and reputational risk associated with a virtual asset business. 

Facilitates business credibility and trust 

• By appointing a compliance officer who is competent and has the expertise, it lends credibility to the VASP when dealing with customers, or other stakeholders, and financial institutions, which will provide more credibility in accessing partnerships with service providers and dealing with international markets that demand adherence to the standards of actual sector and international counter-terrorism, anti-money laundering obligations globally. 

Supports continuous compliance responsibilities 

• Compliance officers provide support functions for compliance aspects, such as furnishing the FSC with significant changes, providing auditor letters, and submitting financial and client returns and other obligations, that a VASP needs to do to stay in good standing with its regulators. 

Knowledge and awareness of legal and regulatory changes 

• A compliance officer will provide the timeliest knowledge of changes to BVI laws and the ability for a VASP to adjust to the rapid pace of changes and regulatory amendments while remaining in compliance and without disruption to business. 

Supports the licensing process 

• A designated compliance officer may manage and process the documentation, and other administration requirements of VASPs applications and renewal of BVI VASP license applications. 

Corporate governance 

• A compliance officer will ensure that all directors and senior officers are fit and proper, and that the company has governance frameworks that are good with the expectations of the BVI FSC. 

Who should appoint BVI VASP license compliance officer services?

The BVI Virtual Assets Service Providers (VASPs) Act requires the following entities to appoint a compliance officer as part of their licensing and ongoing regulatory obligation:  

For BVI Business Companies that are registered as Virtual Asset Service Providers (VASPs): 

• All BVI VASP applicants, or holders, must appoint a compliance officer that meets the BVI Financial Services Commission (FSC) prescribed standards.  

For registered partnerships operating as VASPs: 

• All partnerships (including limited partnerships) established under BVI law providing virtual asset services are required to appoint a designated qualified compliance officer as part of the licensing requirements. 

For individual VASPs approved in the BVI: 

• In very limited circumstances where individuals are approved by the BVI FSC to provide virtual asset services in or from the BVI, this individual must appoint a qualified compliance officer as required by the BVI FSC. 

Eligibility for BVI VASP license compliance officer services

• Must be an individual appointed by the BVI Financial Services Commission (FSC) for the compliance officer role, according to the VASP Act. 

• Must have relevant skills, knowledge, and experience with AML/CTF and regulatory compliance in the virtual asset space. 

• Must meet all “Fit and Proper” requirements as per the BVI Regulatory Code, demonstrating honesty, integrity, competence, capability, and financial propriety. 

• Must be able to establish, implement, and maintain a robust compliance framework to mitigate risks of money laundering, terrorism financing, and other illicit activities. 

• Must have knowledge of BVI law, VASP regulation, and standards applicable to virtual asset service providers globally. 

• Must be effective as a liaison with the BVI FSC and other related regulatory authorities, to timely submit other reports and notifications as required. 

• Often, they cannot be independent from common corporate compliance officer vehicles and cannot simply be an administrative person but must demonstrate knowledge of the VASP-related compliance duties. 

• May be required to have local residency or presence depending on the nature and risk associated with the VASP, at the discretion of the FSC. 

BVI VASP license compliance officer assistance

• All our compliance officers are Certified Anti-Money Laundering Specialists (CAMS) and Certified Crypto Asset AFC Specialists (CCAS) and have at least 5+ years of experience in the virtual asset and financial services industry. We have full, and operational, knowledge of the BVI VASP Act and the regulatory expectations of the British Virgin Islands Financial Services Commission. Your compliance function truly is in expert hands, fully capable of maintaining rigorous AML/CFT processes and meeting all ongoing regulatory requirements. 

Services offered by Tetra Consultants BVI VASP license compliance officer services

• Be sure that the VASP complies with: 
  • The VASP Act 2022 
  • The Financial Services Commission Act 
  • The applicable AML/CFT laws and regulations 

• Prepare and submit reports to the regulator (including both annual returns and notifications). 

• Develop and maintain compliance manuals, procedures, and controls that meet the expectations of the FSC. 

• Monitor the legal and regulatory frameworks for changes and update policies and procedures where necessary. 

• Design, implement and enforce a comprehensive AML/CFT Framework. 

• Carry out or conduct Customer Due Diligence (CDD/KYC), Enhanced Due Diligence (EDD), and Ongoing Monitoring. 

• Investigate and report Suspicious Activity Reports (SARs) to the BVI Financial Investigation Agency (FIA). 

• Ensure that appropriate transaction monitoring systems are in place for both fiat and virtual asset transactions. 

• Ensure that a VASP license is renewed on a timely basis, and that the FSC is advised on any reportable matter (for example, materials changes, changes in controllers, or changes in business activities). 

• Act as a contact point with the BVI FSC, responding to any regulatory inquiries or inspections. 

• Monitor and manage any cross-border activities, in compliance with applicable law. 

• Take a risk-based approach to compliance and develop a compliance risk assessment. 

• Conduct internal compliance audits or coordinate the completion of external reviews. 

• Maintain a Compliance Monitoring Program and test the control effectiveness of your compliance policies. 

• Deliver regular training to directors, management, and staff on: 
  • AML/CFT procedures 
  • Sanctions compliance 
  • Data protection 
  • Crypto-related risks (e.g., fraud, market abuse) 
  • Retain records of training and employee acknowledgements. 

• Keep proper records of: 
  • Client due diligence 
  • Risk assessments 
  • Transactions 
  • Internal/external compliance reports 

• Be aware of and comply with the minimum 5-year record retention period under AML laws. 

• Provide regular updates to your Board of Directors or governing body on compliance risks, issues, breaches, and controls. 

Steps for appointment of BVI VASP license compliance officer services