Industry Circulars

Industry Circular No: 01 of 2026

Licensing Fees for AMLive

The Financial Investigation Agency (the “FIA”) wishes to remind all relevant persons (which includes regulated persons and entities[ Relevant Person includes but is not limited to, a regulated person as defined under the Anti-Money Laundering Regulations, 2008 and the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008.]) that, as previously communicated via the FIA’s Notice published on its website, a licensing framework for AMLive user access took effect on 1 January 2026. Under this framework, reporting entities are provided with one (1) complimentary user licence to facilitate the submission of suspicious activity/transaction reports (“SARs”) via AMLive. Any additional user licences requested are subject to a fee of $150.00 per licence.
(Relevant Person includes but is not limited to, a regulated person as defined under the Anti-Money Laundering Regulations, 2008 and the Anti-Money Laundering and Terrorist Financing Code of Practice, 2008.)

This Circular serves to formally reiterate the applicable licensing arrangements and provide further clarity on the administration of the fee. This licensing fee applies on a prospective basis and does not affect licenses granted prior to the implementation date.

Introduction

1. The Financial Investigation Agency consists of two (2) arms, the Supervision and Enforcement Unit (“SEU”) and the Analysis and Investigation Unit (“AIU”).
2. The AIU in particular, receives a significant level of highly sensitive and confidential information/intelligence on a daily basis, which includes suspicious activity/transaction reports filed by financial institutions, regulated entities, designated non-financial businesses and professions, non-profit organisations and other persons. The core, operational functions of the AIU includes collecting, investigating, analysing and exchanging financial intelligence and other information, conducting operational and strategic analysis, receiving, analyzing and investigating any suspicious activity/transaction report or other disclosure; and facilitating the sharing of financial intelligence and related information with domestic competent authorities, law enforcement agencies and prosecutorial authorities and foreign financial investigation agencies.
3. By virtue of section 4(2)(a) of the Financial Investigation Agency Act, 2003 (as amended) (the “FIA Act”), the FIA is empowered to receive, analyse and investigate any suspicious activity report or other disclosure made under the Proceeds of Criminal Conduct Act, 1997 (as amended) (“POCCA”) or any other enactment which requires such a report or disclosure. Pursuant to section 4(2)(c) of the FIA Act, the Agency also has the responsibility to receive all disclosures of information required to be made to any financial services legislation or other enactment which is relevant to the performance of its functions or pursuant to any other enactment relating to a financial offence, including information from any foreign financial investigation agency.
4. By virtue of section 6(1) of the Anti-money Laundering and Terrorist Financing Code of Practice, 2008 (as amended) (“AML Code”), the FIA is the reporting authority of the Virgin Islands and is responsible for matter relating to suspicious transaction reports concerning money laundering, terrorist financing and proliferation financing.
5. Further, pursuant to section 30A of POCCA, a person commits an offence if:
   • (a)he knows or suspects or has reasonable grounds for knowing or suspecting that another person is engaged in money laundering;
   • (b)the information or other matter on which his knowledge or suspicions is based or which gives reasonable grounds for such knowledge or suspicion came to his attention in the course of his trade, profession, business or employment; and
   • (c)he does not disclose the information or other matter to the FIA as soon as is reasonably practicable after it comes to his attention.
6. Therefore, all relevant persons are required to disclose suspicious activities/transactions reports to the FIA as soon as is reasonably practicable after it comes to his attention. Failing such, that person commits an offence and is liable:
   • (a)on summary conviction to a term not exceeding 8 years and a fine not exceeding $500,000; and
   • (b)on conviction on indictment to a term not exceeding 20 years and a fine not exceeding $1,500,000.
7. In order to facilitate the efficient filing of suspicious activity/transaction reports, the Agency has established AMLive to process and analyse SARs. A licensing fee of $150.00 per additional user license has been implemented for submissions made via AMLive to support sustainability.
8. The AIU is responsible for the consistent implementation and monitoring of AMLive. All enquiries and reports should be addressed to: