BVI/CAYMAN: New duty to report frozen assets in BVI and Cayman Islands

As published on: STEP.org, Monday 17 November, 2025.

British Virgin Islands (BVI) and Cayman Islands firms that hold or control funds or economic resources for UK-sanctioned designated persons must now file a frozen assets report by 30 November 2025.

Both jurisdictions have published orders for the new reporting obligation, which commences this year. From commencement onwards, these reports must be filed for each year with the BVI Financial Services Commission or the Cayman Islands Financial Reporting Authority.

The reports relate to assets owned, held or controlled by individuals or entities designated for sanctions by the UK government, regardless of whether the entity holds or controls them within the jurisdiction or overseas. The new requirement is in addition to any report of frozen assets already made to the relevant authority in a compliance reporting form.

As well as BVI or Cayman Islands banks holding frozen cash, the orders issued will be relevant to Cayman Islands funds holding underlying assets that are frozen because the designated person owns those assets, holds them (for example, assets held on a settlement depository that is itself a designated person) or controls them. They will also be relevant to assets frozen because the investment fund itself is considered to be owned by a designated person, for example through majority ownership by a designated person.

Affected persons will need to complete the relevant BVI or Cayman Islands forms giving details of the frozen assets and their value as at 30 September 2025. Where the forms are not yet available, they can be made in similar form to the UK template for the corresponding frozen asset report exercise in the UK, according to law firm Maples.

Assets frozen only by other governments, notably the US Office of Foreign Assets Control, do not have to be reported under these orders. Further, ‘nil returns’, where no frozen assets are held, are not required in the Cayman Islands. This may be relevant to persons who have filed a compliance reporting form in relation to sanctioned persons but were not holding or controlling the frozen assets in question.