04 August 2026
Continuing obligations for private and professional funds The board and officers Functionaries and other service providers Service provider Requirement Is an exemption available? Notice requirements Event triggering an obligation to notify the FSC Time frame Annual regulatory and government requirements Due by date Action Maintenance of records and financial statements Fund policies and arrangements Anti-money laundering obligations Obligations under FATCA and CRS? Beneficial ownership regime
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As a recognised fund, your professional or private fund is regulated by the British Virgin Islands (BVI) Financial Services Commission (the FSC). This note provides a quick reference to your professional or private fund's ongoing BVI obligations.
Professional and private funds are recognised under the Securities and Investment Business Act, Revised Edition 2020 and are subject to the Mutual Funds Regulations, Revised Edition 2020.
A professional or private fund must:
At all times have at least two directors, at least one of whom must be an individual
Appoint an appropriately qualified and independent individual as Money Laundering Reporting Officer (MLRO) for the fund who may, in practice, be a person provided by one of the functionaries to the fund (see below for more detail on anti-money laundering obligations)
Appoint a Foreign Account Tax Compliance Act (FATCA) responsible officer and a principal point of contact for the BVI International Tax Authority (ITA)(see below for more detail on obligations under FATCA and CRS)
A private or professional fund is required to have the following functionaries and other service providers:
Manager
A private or professional fund must at all times have a manager.
Yes, in certain circumstances, on application to the FSC.
Administrator
A private or professional fund must at all times have an administrator.
No exemption is available.
Custodian
A private or professional fund must at all times have a custodian. The custodian must be functionally independent from the manager and administrator.
Yes, in certain circumstances, on application to the FSC.
The most common exemptions are for feeder funds in a "master-feeder" structure and for funds whose prime broker provides the custodial services.
Auditor
A private or professional fund must appoint and at all times have an auditor to audit its financial statements.
Yes, in certain circumstances, on application to the FSC.
Authorised Representative
A private or professional fund must have an FSC licenced authorised representative (Authorised Representative) to act as a point of contact between the fund and the FSC.
No exemption is available.
On the happening of certain events, a professional or private fund is required to notify the FSC. The table below summarises these notification requirements and the timeframe for providing notice.
The appointment of a functionary (ie the manager, administrator, investment advisor, custodian, any prime broker or (in the case of a unit trust) the trustee).
Not less than 7 days prior to the date of appointment.
A functionary ceasing to act (notice must include a statement of the reasons for such functionary ceasing to act).
Within 7 days.
The appointment of a director.
Within 14 days.
A director ceasing to hold office (for whatever reason).
Within 14 days.
The appointment of an Authorised Representative.
Within 14 days.
An Authorised Representative ceasing to hold office (for whatever reason).
Within 14 days.
The appointment of an auditor.
Within 14 days.
An auditor ceasing to hold office (for whatever reason).
Within 14 days.
Any change in the address of the fund's place of business, whether in or outside the BVI.
Within 14 days.
Any amendment to its constitutional documents.
Within 14 days.
The issuance of any offering document not previously provided to the FSC.
Within 14 days.
The amendment of any offering document previously provided to the FSC.
Within 14 days.
There are various reporting and payment deadlines for a professional or private fund throughout the year.
31 March
Pay recognition fee of US$1,200 to the FSC. Failure to pay may attract administrative penalties and/or other enforcement action
30 April
For funds that are limited partnerships, pay the Registrar of Corporate Affairs (together with the Registrar of Limited Partnerships, the Registry) licence fee of US$750
31 May
FATCA reporting deadline and Common Reporting Standard (CRS) reporting deadline
31 May
For funds that are companies incorporated ...
Professional and private funds are recognised under the Securities and Investment Business Act, Revised Edition 2020 and are subject to the Mutual Funds Regulations, Revised Edition 2020.
A professional or private fund must:
At all times have at least two directors, at least one of whom must be an individual
Appoint an appropriately qualified and independent individual as Money Laundering Reporting Officer (MLRO) for the fund who may, in practice, be a person provided by one of the functionaries to the fund (see below for more detail on anti-money laundering obligations)
Appoint a Foreign Account Tax Compliance Act (FATCA) responsible officer and a principal point of contact for the BVI International Tax Authority (ITA)(see below for more detail on obligations under FATCA and CRS)
A private or professional fund is required to have the following functionaries and other service providers:
Manager
A private or professional fund must at all times have a manager.
Yes, in certain circumstances, on application to the FSC.
Administrator
A private or professional fund must at all times have an administrator.
No exemption is available.
Custodian
A private or professional fund must at all times have a custodian. The custodian must be functionally independent from the manager and administrator.
Yes, in certain circumstances, on application to the FSC.
The most common exemptions are for feeder funds in a "master-feeder" structure and for funds whose prime broker provides the custodial services.
Auditor
A private or professional fund must appoint and at all times have an auditor to audit its financial statements.
Yes, in certain circumstances, on application to the FSC.
Authorised Representative
A private or professional fund must have an FSC licenced authorised representative (Authorised Representative) to act as a point of contact between the fund and the FSC.
No exemption is available.
On the happening of certain events, a professional or private fund is required to notify the FSC. The table below summarises these notification requirements and the timeframe for providing notice.
The appointment of a functionary (ie the manager, administrator, investment advisor, custodian, any prime broker or (in the case of a unit trust) the trustee).
Not less than 7 days prior to the date of appointment.
A functionary ceasing to act (notice must include a statement of the reasons for such functionary ceasing to act).
Within 7 days.
The appointment of a director.
Within 14 days.
A director ceasing to hold office (for whatever reason).
Within 14 days.
The appointment of an Authorised Representative.
Within 14 days.
An Authorised Representative ceasing to hold office (for whatever reason).
Within 14 days.
The appointment of an auditor.
Within 14 days.
An auditor ceasing to hold office (for whatever reason).
Within 14 days.
Any change in the address of the fund's place of business, whether in or outside the BVI.
Within 14 days.
Any amendment to its constitutional documents.
Within 14 days.
The issuance of any offering document not previously provided to the FSC.
Within 14 days.
The amendment of any offering document previously provided to the FSC.
Within 14 days.
There are various reporting and payment deadlines for a professional or private fund throughout the year.
31 March
Pay recognition fee of US$1,200 to the FSC. Failure to pay may attract administrative penalties and/or other enforcement action
30 April
For funds that are limited partnerships, pay the Registrar of Corporate Affairs (together with the Registrar of Limited Partnerships, the Registry) licence fee of US$750
31 May
FATCA reporting deadline and Common Reporting Standard (CRS) reporting deadline
31 May
For funds that are companies incorporated ...