Suriname and British Virgin Islands: A 2025 FATF Progress Report

suriname british virgin islands cfatf caribbean report 2025

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The Caribbean Financial Action Task Force has released updated evaluations regarding the progress of regional jurisdictions in combating illicit financial activities through technical compliance re-ratings. These reports detail the legislative and operational improvements made by Suriname and the British Virgin Islands through May 2025. Both territories have undergone significant technical compliance re-ratings to address previously identified gaps in their regulatory frameworks. The findings highlight a concerted effort to align domestic laws with international standards for transparency and risk mitigation.

Technical Compliance Re-Ratings

The Caribbean Financial Action Task Force assessed the progress of both nations in meeting the rigorous criteria set forth by global regulators. For the British Virgin Islands, the second enhanced follow-up report notes successful re-ratings for four key recommendations, including significant upgrades for non-profit organization oversight. Suriname’s third enhanced follow-up report reflects its ongoing commitment to rectifying deficiencies in its financial system, particularly regarding the reporting of unusual transactions. These re-ratings are awarded only when a jurisdiction demonstrates sufficient progress in its technical compliance requirements.

Advancements in the British Virgin Islands

The British Virgin Islands has a history of addressing deficiencies identified in its 2023 Fourth Round Mutual Evaluation Report, where it was placed under enhanced follow-up after receiving low or moderate effectiveness ratings in seven out of eleven outcomes. Historically, the jurisdiction struggled with Recommendation 8, originally rated as non-compliant due to a failure to identify the subset of non-profit organizations at risk for terrorist financing. To rectify these long-standing issues, the territory published a detailed risk assessment for the sector in August 2024, identifying specific threats related to the collection and transfer of funds. Recent legislative amendments to the Financial Investigation Agency Act have further empowered authorities to apply risk-based supervision to entities most vulnerable to abuse. The jurisdiction has also focused on enhancing transparency for legal persons, ensuring that basic and beneficial ownership information is more accessible to competent authorities. Further, the territory updated its National AML/CFT/CPF Policy in 2024 to ensure risk assessments are reviewed every three years.

Regulatory Enhancements in Suriname

Suriname’s compliance history is marked by its 2022 Mutual Evaluation Report, which placed the country in enhanced follow-up after it met the threshold for eight or more non-compliant or partially compliant ratings. The nation has since moved through several follow-up cycles, achieving re-rating upgrades for twelve recommendations between 2023 and 2024. A major historical gap was addressed through the enactment of the WMTF Act, which repealed the older WID Act to consolidate anti-money laundering and counter-terrorist financing mandates into a single framework. This legislation requires service providers to report unusual transactions to the financial intelligence unit without delay and to implement enhanced customer due diligence measures. Suriname also established the FIU Suriname as an autonomous body and joined the Egmont Group in May 2024. While progress has been documented in the oversight of precious stone dealers and life insurance providers, certain deficiencies remain regarding the verification of beneficial owners for complex legal arrangements.

Future Compliance Trajectories

Both jurisdictions remain under enhanced follow-up, a process reserved for members with significant deficiencies in their technical compliance or effectiveness ratings. The British Virgin Islands is scheduled for a reassessment of its non-profit sector in 2027 to maintain the integrity of its risk-based approach. Suriname is focused on finalizing the online declaration system for currency movements and clarifying the duration for which assets can be restrained. The Suriname authorities are also working to update guidance for financial institutions to ensure the immediate communication of de-listing actions and asset unfreezing. Continuous monitoring by regional experts ensures that these territories stay on a path toward full compliance with international standards. The evolution of these frameworks demonstrates a regional priority on securing the financial system against emerging global threats and maintaining international cooperation.

Key Points

The British Virgin Islands was historically placed in enhanced follow-up due to low effectiveness ratings in seven areas during its 2023 evaluation.
Suriname addressed historical legislative gaps by repealing the WID Act and enacting the comprehensive WMTF Act.
Risk-based supervision for the non-profit sector in the British Virgin Islands is now supported by a dedicated 2024 risk assessment.
Suriname has achieved re-rating upgrades for twelve recommendations across its first and second follow-up reports since 2023.
Both territories continue to address remaining gaps in beneficial ownership transparency and the oversight of complex legal constructs.

Source: FATF

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Suriname and British Virgin Islands: A 2025 FATF Progress Report