British Virgin Islands – CM P – Update 2021

Jul 30, 2021

Country Manual Products

BRITISH VIRGIN ISLANDS (BVI)

Please note the following material changes regarding the above-mentioned jurisdiction:

– For consistency purposes with the Country Manual Private Banking (CM PB), any product-related marketing activities as well as provision of any advisory services are now not recommended towards Retail Investors “at target” in the BVI due to the missing license (incl. when based on the written advisory agreement (ongoing advice)). The exception is made for the provision of services upon a specific request of the client (“specific reverse solicitation”), which is still permitted. In all the other scenarios, the CM P BT now provides the answer “Grey zone/NO” (instead of “Grey zone”) for ongoing advice provided actively/upon generic reverse solicitation) and “NO” (instead of “YES”) for spot advice provided with regard to the registered products.
– Further, in alignment with the CM PB, providing advisory services to Retail Investors “without/outside the scope of an advisory agreement (spot advice)” on a cross-border basis (remote) is no longer recommended as it is deemed to trigger licensing requirements. The CM P BT now provides the answer “Grey zone/NO” (instead of “YES”) for all registered products and (instead of “Grey zone”) for advice provided upon request not limited to a specific product (“generic reverse solicitation”).
– Finally, provision of “execution only” services towards Retail Investors is not anymore recommended “at target” in the BVI due to the missing license. The CM P BT now provides the answer “Grey zone/NO” (instead of “Grey zone”) for Retail Investors and “Grey zone/NO” (instead of “YES”) for Professional Investors.

Should you have any questions, please do not hesitate to contact us.

info@brpsa.com

Best regards,