2022 Thematic Inspection Programme

Summary

This notice sets out the British Virgin Islands FSC's Thematic Inspection Programme for 2022, listing the AML/CFT compliance topics its examiners will focus on during onsite and offsite inspections that year, broken down by quarter and by targeted sector.

• Record-Keeping (Transaction Records): Reviewed in the 1st Quarter, targeted at TCSPs; covers awareness of where records are kept, who is responsible for them, ability to retrieve records, and quality of records maintained.
• Internal Audit: Reviewed in the 2nd to 4th Quarter, across all sectors; covers independence and resourcing of the audit function, access to the Board and documentation, and compliance with reporting requirements.
• Sanctions Monitoring: Reviewed in the 2nd to 4th Quarter, across all sectors; covers ability to conduct timely searches of client databases, actions taken on sanctioned clients, and staff knowledge and training.
• Suspicious Activity Reporting: Reviewed in the 2nd and 4th Quarter, across all sectors; covers ability to identify suspicious transactions, internal and external reporting, and related record-keeping.

The document is informational, indicating the FSC's examination priorities and timing rather than creating new standalone rules; entities should ensure existing AML/CFT policies and records are in order ahead of the relevant assessment period.

Applies to

TCSPs, all regulated sectors, DNFBPs

Deadlines

• 1st Quarter: Record-Keeping (Transaction Records) inspection focus, targeted at TCSPs
• 2nd - 4th Quarter: Internal Audit inspection focus, all sectors
• 2nd - 4th Quarter: Sanctions Monitoring inspection focus, all sectors
• 2nd and 4th Quarter: Suspicious Activity Reporting Procedures and Reports inspection focus, all sectors