[{"data":1,"prerenderedAt":-1},["ShallowReactive",2],{"detail-sidebar-cat-0-en-105":3,"doc-seo-500662-105":59,"doc-detail-500662-en":130},{"code":4,"msg":5,"data":6},0,"success",[7,13,18,23,28,33,38,43,48,51,55],{"id":8,"doc_module":4,"doc_module_name":9,"category_name":10,"show_sort_weight":11,"slug":12},1,"Document","Story & Novel",90,"story-novel",{"id":14,"doc_module":4,"doc_module_name":9,"category_name":15,"show_sort_weight":16,"slug":17},2,"Literature",80,"literature",{"id":19,"doc_module":4,"doc_module_name":9,"category_name":20,"show_sort_weight":21,"slug":22},4,"Exam",70,"exam",{"id":24,"doc_module":4,"doc_module_name":9,"category_name":25,"show_sort_weight":26,"slug":27},5,"Comic",60,"comic",{"id":29,"doc_module":4,"doc_module_name":9,"category_name":30,"show_sort_weight":31,"slug":32},6,"Technology",50,"technology",{"id":34,"doc_module":4,"doc_module_name":9,"category_name":35,"show_sort_weight":36,"slug":37},7,"Healthcare",40,"healthcare",{"id":39,"doc_module":4,"doc_module_name":9,"category_name":40,"show_sort_weight":41,"slug":42},8,"Research & Report",30,"research-report",{"id":44,"doc_module":4,"doc_module_name":9,"category_name":45,"show_sort_weight":46,"slug":47},9,"Religion & Spirituality",20,"religion-spirituality",{"id":46,"doc_module":4,"doc_module_name":9,"category_name":49,"show_sort_weight":46,"slug":50},"World Cup","world-cup",{"id":52,"doc_module":4,"doc_module_name":9,"category_name":53,"show_sort_weight":52,"slug":54},10,"Lifestyle","lifestyle",{"id":56,"doc_module":4,"doc_module_name":9,"category_name":57,"show_sort_weight":24,"slug":58},19,"General","general",{"code":4,"msg":60,"data":61},"ok",{"site_id":62,"language":63,"slug":64,"title":65,"keywords":66,"description":67,"schema_data":68,"social_meta":123,"head_meta":125,"extra_data":127,"updated_unix":129},105,"en","bvifsc-thematic-inspection-initial-findings-reliance-on-third-partiesintroduced-business-relationships","BVIFSC Thematic Inspection Initial Findings - Reliance on Third Parties/Introduced Business Relationships","","BVIFSC thematic inspection findings examine TCSPs’ reliance on third parties, also known as introduced business relationships, within the BVI financial services sector. The report outlines key AML/CFT legislative provisions and highlights both benefits and significant risks, including reduced transparency of beneficial ownership and potential misuse for money laundering, terrorist financing, sanctions evasion, fraud, and other financial crimes. Guidance is provided to address compliance gaps and strengthen board-level oversight and risk mitigation.",{"@graph":69,"@context":122},[70,84,105],{"@type":71,"itemListElement":72},"BreadcrumbList",[73,77,79,82],{"item":74,"name":75,"@type":76,"position":8},"https://docshare.wps.com","Home","ListItem",{"item":78,"name":9,"@type":76,"position":14},"https://docshare.wps.com/document/",{"item":80,"name":40,"@type":76,"position":81},"https://docshare.wps.com/document/research-report/",3,{"item":83,"name":65,"@type":76,"position":19},"https://docshare.wps.com/document/bvifsc-thematic-inspection-initial-findings-reliance-on-third-partiesintroduced-business-relationships/500662/",{"url":83,"name":65,"@type":85,"image":86,"author":91,"headline":65,"publisher":94,"fileFormat":97,"inLanguage":63,"description":67,"dateModified":98,"datePublished":99,"encodingFormat":97,"isAccessibleForFree":100,"interactionStatistic":101},"DigitalDocument",{"url":87,"@type":88,"width":89,"height":90},"https://docshare.wps.com/thumbnails/bvifsc-thematic-inspection-initial-findings-reliance-on-third-partiesintroduced-business-relationships/500662.png","ImageObject",300,407,{"name":92,"@type":93},"LangkahRina","Person",{"url":74,"name":95,"@type":96},"DocShare","Organization","application/pdf","2026-10-23","2026-10-03",true,{"@type":102,"interactionType":103,"userInteractionCount":29},"InteractionCounter",{"@type":104},"ViewAction",{"@type":106,"mainEntity":107},"FAQPage",[108,114,118],{"name":109,"@type":110,"acceptedAnswer":111},"What does the report cover regarding TCSPs and third parties?","Question",{"text":112,"@type":113},"The report focuses on TCSPs’ reliance on third parties (introduced business relationships) and how this affects compliance with AML/CFT requirements.","Answer",{"name":115,"@type":110,"acceptedAnswer":116},"What risks are associated with introduced business relationships?",{"text":117,"@type":113},"The report identifies risks such as lack of transparency in beneficial ownership and control, which can enable bad actors to advance criminal activities including ML, TF, fraud, and sanctions evasion.",{"name":119,"@type":110,"acceptedAnswer":120},"What types of compliance gaps did the inspections observe?",{"text":121,"@type":113},"The findings note varying compliance, including deficient or outdated third-party agreements, insufficient evidence of required testing, and concerns about the suitability of introducers and the conduct of CDD/verification.","https://schema.org",{"og:url":83,"og:type":124,"og:title":65,"og:site_name":95,"og:description":67},"article",{"robots":126,"canonical":83},"index,follow",{"doc_id":128,"site_id":62},500662,1791223289,{"code":4,"msg":5,"data":131},{"doc_id":128,"user_id":132,"nickname":92,"user_avatar":133,"doc_module":4,"category_id":39,"category_name":40,"doc_title":65,"doc_description":67,"doc_content":134,"file_id":135,"file_url":136,"file_type":137,"file_size":138,"view_count":29,"is_deleted":4,"is_public":8,"is_downloadable":8,"audit_status":8,"page_count":29,"language":139,"language_code":63,"site_id":62,"html_lang":63,"table_of_contents":140,"faqs":141,"seo_title":142,"seo_description":67,"update_tm":143,"read_time":144},962090893776,"https://ap-avatar.wpscdn.com/davatar_155a257f0dc6eb9ab79c44ca47cae57d","BVIFSC Thematic Inspection Initial Findings-  \nReliance on Third Parties/Introduced Business Relationships  \nBVIFSC Thematic Inspection Initial Findings –Reliance on Third Parties/Introduced Business Relationships  \nIntroduction  \nTrust and Corporate Services Providers (TCSPs) represent a large percentage of the BVI’s financial services industry. A material portion of TCSPs rely on Third Parties (also referred to as Introduced Business Relationships) to facilitate business.  \nThe BVI’s AML/CFT regime is comprehensive of its coverage of reliance on Third Parties. Provisions can be found in the Anti-Money Laundering and Terrorist Financing Code of Practice (AMLTF Code), and the Anti-Money Laundering Regulations (AML Regulations); specific references to which are highlighted within this document. Additional guidance can also be found in the Explanatory Notes in the AMLTF Code. Some of the more specific legislative requirements are listed in Table 1 below.  \nTable 1 – Key Legislative Provisions relating to Reliance on Third Parties  \n\n| Legislative Reference | Requirement |\n| --- | --- |\n| AMLTF Code of Practice – section 31 | Reliance on third parties |\n| AMLTF Code of Practice – section 31A | Contents of Written Agreements |\n| AMLTF Code of Practice – section 31B | Testing of Business Relationship |\n| AML Regulations – regulation 4 | Identification procedures in relation to new and continuing business relationships |\n| AML Regulations – regulation 7 | Reliance on third parties |\n| AML Regulations – regulation 7A | Third party business relationship agreement |\n| AML Regulations – regulation 7B | Obligation to test business relationship |\n\nAs the regulator, the Commission recognises that Introduced Business Relationships provide positive benefits, including the ability for service providers to achieve economies of scale in attracting business. However, these relationships also present significant risks. These risks can be presented in several ways, that ultimately result in a TCSP unknowingly being used to create and service legal persons and legal arrangements for bad actors seeking to advance their criminal activities. Such risks include a lack of transparency in the beneficial ownership and control of legal persons and legal arrangements.  \nThe Commission’s 2024/25 Inspection Plan will cover a number of themes, including the continuation of its review of Reliance on Third Parties, which is the focus of this document. The Commission is providing this findings’ report as guidance to alert TCSPs of gaps observed, as well as regulatory requirements that should be reviewed to achieve a high level of compliance.  \nRisks in Context  \nTCSPs face several risks based on the nature of their business activities. For example, while it is the case that the majority of persons who use the arrangement of introduced business to form business relationships and transact business globally do so for legitimate purposes, there are those that tend to abuse the regime for criminal purposes. In such cases, beneficial ownership and/or control could be obscured to mask illicit activities including ML, TF, PF, sanctions evasion, fraud and other financial crimes. The use of Introduced Business Relationships heightens such risk as these relationships are susceptible to abuse if not properly and effectively administered. On this basis, it is important for TCSPs to ensure transparency and accountability when engaging in such relationships.  \nIt is, therefore, vital for TCSPs to have robust policies and procedures in place to achieve effectiveness in their compliance measures and risk mitigation strategies including those relating to Introduced Business Relationships. Importantly, a TCSP’s compliance function ultimately rests with its Board of Directors. This is clearly set out in the Regulatory Code, 2009, and specifically, at section 26, which sets out the requirement for establishing and maintaining clearly defined policies for the effective management of a","cbCaigiBJLZKKTin","https://ap.wps.com/l/cbCaigiBJLZKKTin","pdf",372516,"English","# Introduction\n## Key Legislative Provisions relating to Reliance on Third Parties\n## Risks in Context\n## Observations from Thematic - Reliance on Third Parties/Introduced Business Relationships","[{\"question\":\"What does the report cover regarding TCSPs and third parties?\",\"answer\":\"The report focuses on TCSPs’ reliance on third parties (introduced business relationships) and how this affects compliance with AML/CFT requirements.\"},{\"question\":\"What risks are associated with introduced business relationships?\",\"answer\":\"The report identifies risks such as lack of transparency in beneficial ownership and control, which can enable bad actors to advance criminal activities including ML, TF, fraud, and sanctions evasion.\"},{\"question\":\"What types of compliance gaps did the inspections observe?\",\"answer\":\"The findings note varying compliance, including deficient or outdated third-party agreements, insufficient evidence of required testing, and concerns about the suitability of introducers and the conduct of CDD/verification.\"}]","BVIFSC Thematic Inspection Initial Findings - Reliance on Third Parties/Introduced Business Relationships | PDF",1791013944,15]