The British Virgin Islands Financial Services Commission issued an implementation update on beneficial ownership filings under the BVI Business Companies and Limited Partnerships (Beneficial Ownership) Regulations 2024 and related guidelines, which require BVI business companies and limited partnerships to file beneficial ownership information with the Registry of Corporate Affairs via the VIRRGIN system from 2 January 2025. The circular responds to technical, legislative and logistical issues raised by registered agents since go live and provides operational clarifications on filings, exemptions and penalties while VIRRGIN functions are rolled out. Batch or bulk filing is scheduled to be available from 17 April 2025, with a bulk filing schema to be shared with agents and tentatively scheduled for completion by 31 March 2025. The Commission clarifies that BTCA licensed trustees should file the name of the licensed trustee, that where a beneficial owner cannot be identified (for example where the parent is a foundation) a Senior Managing Official should be recorded, and that directors, members and beneficial owners can be filed in any order. Supporting documentation is only prompted where names or dates of birth are incomplete, foreign characters are not currently supported, subsidiaries of listed entities are described as exempt but the relevant VIRRGIN function is not yet available, and “bands of interest” are being developed to reduce refilings driven by small percentage changes. On enforcement, no penalties will be charged where a required VIRRGIN function is unavailable if the Registry is notified and provided with a list of affected entities, and penalty days are counted as clear calendar days including weekends and holidays. An updated schedule for phased release of VIRRGIN functions is available on the Commission’s website and may change. The Commission also plans to update its FAQs by the second week of March and periodically thereafter, including further guidance on bulk filing, trustees and exempt subsidiaries and listed companies.

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