New Annual Frozen Asset Reporting Requirement In The BVI: What You Need To Know

• Published date: 03 December 2025
• Law Firm: Walkers
• Author: Ms Lucy Frew and Iona Wright

Key takeaways

• On 20 November 2025, the VISU published a notice requiring all BVI entities which hold or control funds or economic resources controlled, held or owned by a Designated Person to file a new annual report by 30 November 2025.

• BVI entities must use the template annual reporting form provided by the VISU. Details of the frozen assets must reflect the position as at 30 September 2025.

• This new annual reporting requirement is in addition to existing obligations to report frozen assets to the VISU. Annual frozen asset reports must now be filed each year.

Frozen asset reporting: New requirement

The UK Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024 amended the sanctions regimes to introduce a new reporting obligation that applies to all persons that hold or control funds or economic resources controlled, held or owned by a person designated under UK sanctions (a Designated Person).

On 20 November 2025, the Virgin Islands Sanctions Unit (the VISU) published a notice in relation to frozen asset reporting clarifying the extension of this frozen asset reporting requirement to the British Virgin Islands (BVI). The notice is available here.

What does your entity need to do under the...