Application and Declaration for Extension of Time - Beneficial Ownership

Summary

This is a fillable form issued by the BVI Financial Services Commission allowing a 'relevant person' (typically a registered agent) to apply for an extension of time to complete beneficial ownership information collection for the companies it acts for, under paragraph 4 of the Schedule to the Anti-money Laundering Regulations, 2008. The applicant must disclose the state of its beneficial ownership compliance across active and struck-off companies and justify the need for extra time.

• Company counts: Applicant must state the number of active companies it acts for, and separately the number of struck-off companies with which it has an existing business relationship.
• Beneficial ownership status: Applicant must report, for both active and struck-off companies, how many already have beneficial ownership information obtained and maintained versus how many still lack it, plus percentage breakdowns of completion.
• Extension period requested: Applicant must specify the length of extension sought, which may not exceed 6 months from 1 January 2017.
• Justification and evidence: Applicant must state the reasons for requesting the extension and may attach supporting evidence.
• Declaration: A director or senior manager of the applicant must sign a declaration confirming the information in the form is true and accurate, and the person submitting the application (if different) must also sign.

Because the stated extension window runs from 1 January 2017, this form relates to a historical compliance deadline for beneficial ownership record-keeping under the 2008 AML Regulations rather than an ongoing filing requirement; readers should check with the FSC whether this form remains in current use before relying on it.

Key obligations

• A relevant person seeking more time to obtain and maintain beneficial ownership information must submit this application disclosing the number of active and struck-off companies it acts for and their beneficial ownership compliance status.
• The applicant must specify the extension period requested, which cannot exceed 6 months from 1 January 2017, and must state the reasons for the request, providing supporting evidence where available.
• A director or senior manager of the applicant must sign a declaration attesting that the information in the form is true and accurate.

Applies to

relevant persons (registered agents) under the Anti-money Laundering Regulations, 2008, companies for which beneficial ownership information must be obtained and maintained

Deadlines

• not more than 6 months from 1st January, 2017: Maximum period of extension that may be requested for completing beneficial ownership information collection and maintenance