REGARD ALL BVI CORPORATIONS AS BENEFICIALLY OWNED BY RUSSIAN OLIGARCHS UNTIL PROVEN OTHERWISE

The new Russian Oligarch tactic, to transfer beneficial ownership of a substantial portion of their assets to opaque British Virgin Islands companies that they control, when coupled with the reluctance of BVI local government to disclose what companies they control, has led us to the conclusion that compliance officers must now regard ALL BVI companies as Russian-owned, unless and until proven otherwise by competent evidence.

Reportedly, there was an internal investigation, with predictable results that disputed the massive transfers, but which was conducted under secret conditions which make it suspected to be a whitewash, and an effort to cover up the truth. Apparently, the UK Foreign Office is attempting to obtain details of the findings, but given the BVI's long and sordid history of banning investigative journalists from the island, and deporting those who have the temerity to show up, we doubt that the allegedly corrupt local government officials will be forthcoming with the information, even though UK law applies.

Therefore, given that the element of risk is elevated, due to the global sanctions imposed upon Russian Oligarchs, who support the Russian regime that launched the invasion of the Ukraine, and that Enhanced Due Diligence will be inadequate, in ruling out Oligarchs as beneficial owners of specific BVI companies, it is strongly suggested that compliance officers at all EU, UK and North American financial institutions redline all BNVI companies, until an effective procedure can be found to guarantee beneficial ownership, current to the day of inquiry.

Compliance has bee dealing with BVI obstruction of information for decades; the opaque nature of the island's companies now require that you determine that the risk levels are simply too high for you to accept as a gatekeeper. Rejection of all BVI companies has become the prudent action, without exception. Do not end up being the subject of a massive regulatory fine, or worse, when your inaction is deemed willful blindness. Govern yourselves  accordingly, ladies & gentlemen.