The British Virgin Islands Financial Services Commission (BVI FSC) has issued guidance advising financial institutions and designated non-financial businesses and professions (DNFBPs) on how they should conduct ongoing monitoring of customers, including companies, trusts or other entities.

Continuous monitoring of customers is regarded by the Financial Action Task Force (FATF) as an essential part of financial institutions' duties to identify elevated risks, unusual or suspicious transactions and breaches of financial sanctions. It requires effective and ongoing monitoring of transactions and business relationships. Companies must watch for activities that may indicate changes in customer circumstances that: are inconsistent with their known customer profile; are complex or unusually large; form an unusual pattern; or represent higher risk for money laundering, terrorist financing or proliferation financing.

A recent compliance report by the BVI FSC identified ongoing monitoring as an area in need of improvement in the BVI's financial sector. It especially noted 'piece-meal' approaches to risk-sensitive or periodic reviews, with some licensees not fully reviewing all aspects of key due-diligence information such as sources of funds and nature of business activities. There was also some evidence of failure to spot trigger events. These included changes to the control or ownership structure, changes in the pattern of services requested, or occurrences where deposits or transactions originate from a high-risk jurisdiction. The FSC also found room for improvement in the level of ongoing screening, specifically for targeted financial sanctions, especially within the trust and company service provider sector.