| Approved Manager | An approval pathway for providing investment management or investment advisory services to legally eligible funds and related structures; it is not a full SIBA Category 3 licence and does not cover banking, money services, insurance, payments, custody-type VASP activities or investment clients of any kind. | There is no verified uniform minimum paid-up capital. The aggregate amounts of US$400m for private/professional funds and US$1bn for closed-ended funds are limits on assets under management, not an applicant’s minimum capital. | The company must continuously have at least two directors (one of whom must be a natural person) and one FSC-certified authorised representative. The personnel performing day-to-day investment functions, AML/CFT arrangements and the MLRO should be determined according to applicable rules and the actual business. | As a general rule, a complete application must be submitted at least 7 days before the intended commencement of business. If the statutory conditions are met, the relevant business may be conducted temporarily while the application is pending from the submission date for up to 30 days; the FSC may extend this by up to a further 30 days. This mechanism is not final approval or a promise of approval. | Monitor open-ended fund AUM and closed-ended fund committed capital separately, notify the FSC promptly after exceeding a limit and assess conversion. Submit the annual return to the FSC by 1/31 each year, generally submit financial statements within 6 months after the financial year-end, and continuously maintain the authorized representative, directors, AML/CFT arrangements and change notifications. |
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| SIBA Investment Business Licence (Category 1–7) | Applies to standard investment business such as dealing in investments, arranging deals, investment management, investment advice, investment custody, investment administration, or operating an investment exchange; a licence authorizes only the listed categories and subcategories. | There is no uniform fixed minimum capital applicable to all Category 1–7. The FSC reviews capital and financial resources based on the nature, scale and complexity of the business, client assets, risks and case-specific conditions. Category 3-D concerns the management of insurance products; it is not an insurance licence. | Directors, senior officers and significant interest holders are subject to fit-and-proper review. The general compliance framework must provide for an approved CO, AML/CFT functions and a certified authorised representative, subject to their actual responsibilities and any applicable exemptions. | There is no fixed review period that can be promised externally; the relevant investment business may be conducted only after the FSC has issued the licence in writing, the conditions have been met and the permitted categories have been specified. | Maintain financial soundness, risk-commensurate capital/insurance, governance and compliance controls on an ongoing basis. Acquisitions or disposals of significant interests usually require prior written FSC approval; category extensions, personnel, reporting and company-register matters must be handled separately under the applicable rules. |
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| VASP virtual asset service registration | Applies to providing another person with virtual-asset and fiat-currency/virtual-asset exchange, transfers on behalf of clients, custody or control of access instruments, and financial services relating to an issuer’s offer or sale. General VASPs, custodial VASPs and exchanges are subject to different registration and risk requirements. | There is no uniform minimum paid-up capital applicable to all VASPs. The FSC assesses capital, projections, insurance or possible regulatory deposit arrangements in light of business scale, customer assets, liquidity, and technology and cyber risks. | Corporate directors must not be used. Arrangements for directors, senior officers, CO, MLRO, auditor and authorised representative must be commensurate with business risk. An FSC-approved authorised representative must be continuously appointed, except where there is a significant BVI management presence. | Review of a registration application depends on the business, technology, ownership look-through and supplementary materials. Regulated VASP services may not be commenced or advertised as approved before registration has been granted. | Maintain the identification, segregation and accounting of client assets, and operate AML/CFT, sanctions, technology security, business continuity and record-keeping systems. An auditor must remain in office unless an exemption is granted; the audit report is generally due within 6 months after the financial year-end. Also handle annual returns, renewals and material changes. |
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| Banking Business Licence | It applies to banking business that involves accepting deposits withdrawable or repayable on demand and using those deposits for lending, credit, guarantees or investment, with the accepting institution bearing the risk. The categories are General, Restricted Class I and Restricted Class II. Classification is not based on whether the service is called payments, currency exchange or “digital banking.” | The published minimum paid-up capital is US$2m for General Banking and US$1m each for Restricted Class I and II. All three classes are subject to higher case-specific capital requirements and risk-weighted capital adequacy requirements. | Before approval, a BVI principal office must be designated, and the names of two authorised agents approved by the FSC and resident in the BVI must be notified. The board, management, CO and MLRO must demonstrate effective governance, risk-management and compliance capabilities. | There is no fixed licensing timeline that can be promised; operations should commence only after the FSC has issued the licence in writing and all licensing conditions have been met. | Maintain ongoing arrangements for capital, liquidity, risk, audit, financial and regulatory reporting, AML/CFT and economic substance. Changes to significant or controlling interests, the principal office and authorised agents, among other matters, may separately trigger prior approval or notification requirements. |
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| Trust and Company Service Provider (TCSP) / Private Trust Company (PTC) | Where trust or company management services are provided on an ongoing basis to third parties, assess TCSP (Class I–V and restricted categories). A PTC is subject to a statutory exemption applicable, under strict conditions, to related trusts or unpaid trust business; it is not a TCSP licence permitting business with the public. | TCSP capital, insurance and financial resources are assessed by licence category, business risk and FSC requirements; a single unverified amount should not be applied across the board. PTC registration fees or company capital are not equivalent to TCSP regulatory capital. | A TCSP should demonstrate that key arrangements are in place for resident directors, senior management, the CO, MLRO, authorised representative and audit. A PTC must continuously appoint a registered agent holding a Class I Trust Licence, who assists in verifying ongoing compliance with the exemption conditions. | For complete TCSP applications, the FSC lists target service standards of 10 weeks for Class I/II/III and 6 weeks for restricted Class II/III. Neither is a guarantee of approval; whether a PTC qualifies for an exemption must also be verified based on the facts. | The TCSP annual renewal fee and TCSP Annual Return should ordinarily both be dealt with by 1 month 31 day each year. A PTC must continue not to solicit business from the public, engage only in related or unremunerated trust business, and retain supporting documents. Significant-interest or control changes must be assessed in advance. |
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| Licensing of insurers, insurance managers and insurance intermediaries | Insurance company Categories A–F, an Insurance Manager and an Insurance Intermediary are distinct routes: A–F are all insurance company categories; managers, insurance brokers and insurance agents are licensed separately under section 40 of the Insurance Act. | There is no single amount applicable to all insurance companies. The verified minimum paid-up capital for a captive insurer is US$100,000 for general insurance and US$200,000 for long-term insurance; insurance managers and intermediaries each require at least US$25,000. The FSC may increase these amounts based on risk, and solvency must be maintained. | Directors, senior officers and persons with significant or controlling interests must undergo fitness and propriety screening. Insurance managers and intermediaries must continuously have an approved designated representative who is actually resident in the BVI, and must arrange CO, MLRO, audit and actuarial functions in accordance with the applicable rules. | There is no uniform number of days that can be promised externally for a decision; underwriting, arranging insurance, or operating as a licensed manager/intermediary is permitted only after the licence has been formally issued and its conditions are satisfied. | Maintain capital, solvency, reinsurance, audit, and financial statements; applicable financial statements are generally filed with the FSC within 6 months after the financial year-end. Insurance renewal fees apply according to category, SPC status, and the prior year's premium basis; changes in control, product category, and key personnel must be handled separately. |
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| Financing and Money Services Licence (FMS) | These requirements apply to funds transmission (including electronic/mobile payments), cheque cashing/currency exchange, financing, financial leasing and ATM businesses. Classes A to E correspond to different statutory functions. The current availability of Class F/G cannot be inferred solely from old announcements or fee schedules; written confirmation should first be obtained from the FSC. | The FMS Act requires the maintenance of prescribed capital resources and financial soundness, but current research has not confirmed a uniform minimum paid-up capital applicable to all categories and models. Customer funds, projected scale and risk affect resource requirements. | A BVI licensee must continuously have at least two natural-person directors. Written FSC approval must be obtained before appointing a director or officer, and CO, MLRO, auditor and an approved BVI principal office must be arranged in accordance with applicable rules. | There is no fixed approval timeline that can be transferred or promised. The FMS application must not be subject to the Approved Manager 7-day / 30-day mechanism. Business may commence only after the FSC has issued a written licence and all conditions have been satisfied. | Maintain records at the approved BVI principal office; generally submit audited financial statements to the FSC within 6 months after the financial year-end; retain transaction records for at least 5 years; and maintain client-money segregation, reconciliations, AML/CFT, audit and prior-approval mechanisms for material interests. |
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| Fund recognition and registration (Private, Professional, Public, Incubator, Approved, PIF) | Recognition or registration of the fund product and fundraising structure: Private, Professional, Incubator, Approved and PIF funds are generally recognized by the FSC; Public Funds are registered by the FSC. The fund route does not automatically authorize the manager, adviser, custodian or distributor to conduct their respective regulated activities. | Fund investor numbers, net assets, minimum initial investment or committed capital are category-screening criteria, not a universal minimum paid-up capital requirement. For example: Incubator Fund, 20 investors/US$20m/US$20,000 per investor; Approved Fund, 20 investors/US$100m; Professional Fund, generally US$100,000 per investor; a PIF is a closed-ended structure. | The directors or general partner are responsible for fund governance; authorized representatives, auditors, fund managers, administrators, and custodians should be appointed as required by the fund category. Management or investment advisory activities must be separately assessed under SIBA, the Approved Manager regime, or another applicable pathway. | The conditions for recognition, registration and commencement of business vary by fund category. There is no approval timeline that can be promised for all funds, and submitting an application does not confer unconditional authorization to operate. | Continuously monitor investor numbers, fundraising methods, redemption rights, net assets and the boundaries of the fund category. The applicable categories generally require financial statements to be submitted to the FSC within 6 months after the financial year-end, and require arrangements for audit, valuation, custody, AML/CFT, service providers and change notifications to be maintained. |
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