Understanding Unregulated Trusts

Published date13 May 2025
Law FirmIcaza Gonzalez-Ruiz & Aleman
AuthorEstefanía Alem'n

Key Considerations and Compliance Guidelines for Unregulated Trusts in the BVI

What is an Unregulated Trust?

An unregulated Trust is a Trust in which the Trustee is a private individual or private company that is not supervised by any regulatory authority.

This memorandum explores:

  • Whether an unregulated Trustee can act simultaneously as Settlor, Trustee, and Beneficiary (a potential conflict of interest known as a "triple role").
  • Recommendations to prevent unregulated Trusts from being considered sham Trusts if challenged in court.
  • BVI Compliance rules for beneficial ownership.

Risks: When Unregulated Trusts May Be Considered Sham or Invalid

An unregulated Trust may be deemed invalid in the following scenarios:

  1. Triple Role Conflict: The same...

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