Administrative Penalty in the total amount of $175,000 and Warning Letters - SHRM TRUSTEES (BVI) LIMITED (2026-05-01)

Summary

This is an enforcement notice published by the BVI Financial Services Commission announcing the outcome of an AML/CFT compliance review of SHRM Trustees (BVI) Limited. The regulator imposed administrative penalties totalling $175,000 and issued four separate warning letters for breaches of the Anti-Money Laundering Terrorist Financing Code of Practice, 2008 (AMLTF Code) and the Regulatory Code, 2008.

• Sanctions screening failure: Breach of s.11(3)(ub) of the AMLTF Code for failing to implement systems and procedures for sanctions screening, monitoring and reporting.
• Risk assessment failure: Breach of s.12(1) of the AMLTF Code for failing to carry out an institutional risk assessment.
• Enhanced due diligence failure: Breach of ss.20 and 22 of the AMLTF Code for failing to conduct Enhanced Customer Due Diligence, including for Politically Exposed Persons.
• CDD review failure: Breach of ss.21(b) and 21(1)(c)(i) of the AMLTF Code for failing to review and keep customer due diligence up to date.
• Warning letters: Four warning letters were issued for the same categories of contravention under the AML Regulations, AMLTF Code of Practice and Regulatory Code, 2008.

The action, recorded under Matter ID ENF050126/020, is dated 1 May 2026 and applies specifically to SHRM Trustees (BVI) Limited; it does not create new general rules but illustrates the Commission's enforcement priorities around sanctions screening, risk assessment, PEP due diligence and CDD maintenance for trust service providers.

Key obligations

• SHRM Trustees (BVI) Limited is required to pay the aggregate administrative penalty of $175,000.00 imposed by the Commission for the identified AMLTF Code contraventions.

Applies to

trust companies, trustees