On 12 November 2026, the BVI Financial Services Commission (FSC), the Financial Investigation Agency (FIA) and the Virgin Islands Sanctions Unit (jointly, “the Authorities”) issued a joint Industry Circular 33 of 2026, drawing the attention of financial institutions (FIs) and designated non-financial businesses and professions (DNFBPs) to the reinstatement of United Nations sanctions concerning Iran following activation of the snapback mechanism, subsequent developments, and associated money-laundering, terrorist-financing and proliferation-financing (ML/TF/PF) risks. This note summarises the public circular — general information / a compliance reminder only, not legal, sanctions-compliance or tax advice.
Key point: The circular is addressed to FIs and DNFBPs. It does not announce a new incorporation or renewal form, and it should not be read as automatically designating any individual BVI company as a sanctioned person. Per the circular, previously lifted UN sanctions were reinstated on 27 September 2025; the United Kingdom later updated its Iran nuclear sanctions framework in 2025 and again in September 2026. In the Virgin Islands, the regime is implemented through the Iran (Sanctions) (Nuclear) (Overseas Territories) Order 2020 (S.I. 2020 No. 1563). Rely on the circular text and the applicable legislation.
Background (as stated in the circular)
The circular recites that in July 2015 the UN Security Council adopted UNSCR 2231, endorsing the Joint Comprehensive Plan of Action (JCPOA) and establishing the snapback mechanism. On 28 August 2025, France, Germany and the United Kingdom initiated the mechanism, citing Iran’s significant non-performance of its nuclear-related commitments. Previously lifted UN sanctions were reinstated on 27 September 2025, restoring the provisions of UNSCRs 1696 (2006), 1737 (2006), 1747 (2007), 1803 (2008), 1835 (2008) and 1929 (2010), and re-establishing the UN Security Council Committee pursuant to Resolution 1737 (2006) and its associated sanctions list. Reinstated measures include asset freezes against designated individuals and entities, restrictions relating to specified nuclear and ballistic missile-related activities, and other financial and trade-related restrictions.
Subsequent UK amendments and Virgin Islands law
- The United Kingdom updated its framework with the Iran (Sanctions) (Nuclear) (EU Exit) (Amendment) Regulations 2025 and, in September 2026, the Iran (Sanctions) (Amendment) Regulations 2026.
- The 2020 Overseas Territories Order extends the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 to the Virgin Islands. The circular asks FIs and DNFBPs to refer to the legislation applicable in the Territory (including amendments) and to official notices, and encourages reference to FSC Sanctions Circular No. 91 of 2025 or FIA Circular No. 88 of 2025 (both issued on 1 October 2025).
- It also notes the Financial Action Task Force’s (FATF’s) continued identification of Iran as a high-risk jurisdiction.
Points for FIs and DNFBPs
The circular says firms should consider the implications for existing relationships, transactions and risk exposure, and in particular should: review sanctions screening arrangements and consider whether existing customers, beneficial owners, counterparties and relationships require reassessment; assess exposure to Iran-related risks; apply customer due diligence and, where required, enhanced due diligence under applicable AML/CFT/CPF rules; remain alert to evasion typologies such as intermediaries, complex or indirect ownership, and multi-jurisdiction transactions; comply with applicable asset-freezing, prohibition, reporting and other measures (including any exceptions or licences); and maintain records of risk assessments, screening results, decisions and actions taken. These considerations are said to be particularly relevant to FIs and DNFBPs involved in international financial transactions, trust and company services, and corporate structures. Firms should keep monitoring official updates.
Practical tips for Hong Kong owners / company secretaries
- The circular does not name individual BVI companies — its primary audience is FIs and DNFBPs (including trust and company service providers, such as registered agents). Do not assume that “no direct Iran business” makes the circular irrelevant, and do not assume that any given entity is itself designated.
- If a registered agent or bank asks for updated KYC or beneficial-ownership information, reply accurately and promptly, and check that records match the current structure, control and counterparties.
- Cross-border, multi-layered or intermediated holdings are among the typologies flagged for heightened attention; take qualified advice where needed. This article does not speculate about particular listings, licences or deadlines.
- Annual financial-return obligations (see our Circular 31 guidance note) are separate from sanctions / AML compliance. Keep watching further notices from the FSC, FIA and the Sanctions Unit.
Sources: FSC Industry Circular 33 of 2026 · BVI FSC Industry Updates
Related services: BVI & offshore company services · Annual examination / company renewal · Accounting · Hong Kong profits tax filing
Related: BVI financial-return Guidance (Circular 31) · BVI ES / VIRRGIN fees · BVI economic substance renewal · BVI company overview