Financial Services (Prudential and Statistical Returns) (Amendment) Order 2025

VIRGIN ISLANDS FINANCIAL SERVICES (PRUDENTIAL AND STATISTICAL RETURNS) (AMENDMENT) ORDER, 2025 ARRANGEMENT OF SECTIONS SECTION

1. Citation
2. Section 10 amended
3. Schedule 3 revoked and substituted
4. Schedule 10 amended

2 VIRGIN ISLANDS STATUTORY INSTRUMENT 2025 NO. 87 FINANCIAL SERVICES COMMISSION ACT (REVISED EDITION 2020) Financial Services (Prudential and Statistical Returns) (Amendment) Order, 2025 [Gazetted 30th September, 2025] The Financial Services Commission, acting in accordance with the powers conferred on it by section 56A of the Financial Services Commission Act, Revised Edition 2020, makes the following Order: Citation

1. (1) This Order may be cited as the Financial Services (Prudential and Statistical Returns) (Amendment) Order, 2025. (2) This Order shall come into effect on the 1st day of October 2025. Section 10 amended
2. The Financial Services (Prudential and Statistical Returns) Order, Revised Edition 2020 (hereinafter referred to as “the principal Order”), is amended in section 10 by deleting the words “Schedule 5” wherever they appear, and substituting the words “Schedule 10”. Schedule 3 revoked and substituted
3. The principal Order is amended by revoking Schedule 3 and substituting the following Schedule: “SCHEDULE 3 [Section 4] TRUST AND CORPORATE SERVICES PROVIDER ANNUAL RETURN The Trust and Corporate Services Provider Annual Return is to be completed and filed with the Financial Services Commission by the following regulated persons, within 1 month after the end of each calendar year (a) a person holding any of the following licences issued pursuant to the Banks and Trust Companies Act, Revised Edition 2020 (i) Class I Trust licence

3 (ii) Class II Trust licence (iii) Class III licence (iv) Class IV trust licence (v) Class V licence (vi) Restricted Class II Trust licence (vii) Restricted Class III licence; and (b) a person holding a licence issued pursuant to section 4(3) of the Company Management Act, Revised Edition 2020.

4 BVI FINANCIAL SERVICES COMMISSION TRUST AND CORPORATE SERVICES PROVIDER ANNUAL RETURN Banks and Trust Companies Act, Revised Edition 2020 Company Management Act, Revised Edition 2020 Financial Services (Prudential and Statistical Returns) Order, Revised Edition 2020 Name of Licensee: Licence Number: Licence Type Class I Trust ☐ Class V ☐ (Tick as applicable): Class II Trust ☐ Restricted Class II Trust ☐ Class III ☐ Restricted Class II ☐ Class IV Trust ☐ Company Management ☐ Reporting Year: Registered Agent: Registered Office Address: Jurisdictions in which the licensee’s operations are based:

5 INSTRUCTIONS The Trust and Corporate Services Provider Annual Return forms a part of the Financial Services (Prudential and Statistical Returns) Order, Revised Edition 2020, and is required to be filed with the Financial Services Commission on or before 31 January, annually, in respect of the preceding year. The licensee is required to complete all sections of the Trust and Company Services Provider Annual Return that are applicable to the type of licence that the licensee holds. The data should cover the business operations and activities of the licensee for the relevant reporting year; that is, 1 January to 31 December of each year. The regulated entity should refer to the 'Guidance on Preparing and Submitting Trust and Corporate Services Provider Annual Return' for guidance. [click here]

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1. FINANCIAL INFORMATION 1.1 Summary of Balance Sheet Information (US Dollars ONLY) Current Assets Current Liabilities 1.1.1 Cash and cash equivalents 1.1.16 Amounts due to related parties 1.1.2 Funds held for clients/in trust 1.1.17 Funds due to clients 1.1.3 Accounts receivable – clients 1.1.18 Licence fees invoiced – not received 1.1.4 Amounts due from related parties 1.1.19 Licence fees received – not paid to FSC 1.1.5 Short Term Investments 1.1.20 Trade and other payables 1.1.6 Trade and other receivables 1.1.21 Deferred Income 1.1.7 Other Current Assets 1.1.22 Other Current Liabilities 1.1.8 Total Current Assets 1.1.23 Total Current Liabilities Non-Current Assets Non-Current Liabilities 1.1.9 Fixed Assets 1.1.24 Amounts due to related parties 1.1.10 Amounts due from related parties 1.1.25 Deferred Income 1.1.11 Long Term Investments 1.1.26 Other Non-Current Liabilities 1.1.12 Deposit with FSC 1.1.27 Total Non-Current Liabilities 1.1.13 Other Non-Current Assets 1.1.14 Total Non-Current Assets 1.1.28 Total Liabilities 1.1.15 Total Assets Shareholders’ Equity 1.1.29 Share Capital 1.1.30 Contributed Capital 1.1.31 Retained Earnings 1.1.32 Other Reserves 1.1.33 Total Liabilities & Shareholders' Equity 1.2 Contingent Liabilities 1.2.1 Are there any contingent liabilities (for example, pending litigation) which were not reported in the licensee's last audited financial statements or otherwise reported to the Commission? Select (Yes or No) 1.2.2 If yes, please provide details below: 1.3 Financial Ratios Provide the financial soundness indicators listed below: 1.3.1 Liquidity Ratio (Current Assets / Current Liabilities) 1.3.2 Debt Ratio (Total Debt / Total Assets)
2. CAPITAL 2.1 Total number of shares issued to date: 2.2 Value of paid-up capital: 2.3 Institution where paid-up capital is being held: Name: Address: 2.4 Form in which paid-up capital is held:

7 3. PROFESSIONAL INDEMNITY INSURANCE Select (Yes or No) 3.1 Does the licensee maintain Professional Indemnity Insurance (PII)? 3.2 If the response to 3.1 is yes, complete items 3.2.1 to 3.2.6 below: Select (Yes or No) 3.2.1 Has the licensee's PII coverage changed from the previous reporting year? 3.2.2 Provide details of the licensee's PII coverage during the reporting year below: Name of Insurer Jurisdiction of Insurer Level of cover Level of excess payable Territorial limits Details of any exclusions Policy Effective Date Policy Expiration Date Details of any reinstatement Select (Yes or No) 3.2.3 Has the PII coverage been reassessed during the reporting year to ensure that it is appropriate, taking into account the nature, size, complexity, structure and diversity of the licensee's business? If yes, last policy assessment date: 3.2.4 Number of notifications made by the licensee to the insurer relating to potential claims during the reporting year: 3.2.5 Details of claims paid to the licensee by the licensee's insurer during the reporting year: Number of Claims: Total Value of Claims: Select (Yes or No) 3.2.6 Has the licensee's PII coverage lapsed at any time during the reporting year?

8 4. FITNESS AND PROPRIETY Select (Yes or No) 4.1 Was the licensee or any of its beneficial owners, controllers, general partners, shareholders, directors or senior officers convicted of any criminal offence by a court of law during the reporting year? 4.2 Was the licensee or any of its beneficial owners, controllers, general partners, shareholders, directors or senior officers the subject of a criminal investigation or extradition request during the reporting year? 4.3 Was the licensee or any of its beneficial owners, controllers, general partners, shareholders, directors or senior officers censured or disciplined by any professional body to which they belong or belonged during the reporting year? 4.4 Were any of the licensee's beneficial owners, controllers, general partners, shareholders, directors or senior officers dismissed from office or employment or refused entry to any profession or occupation, during the reporting year? 4.5 Did the licensee or any of its beneficial owners, controllers, general partners, shareholders, directors or senior officers file for bankruptcy or were adjudicated bankrupt by any court, during the reporting year? 4.6 Did the licensee or any of its beneficial owners, controllers, general partners, shareholders, directors or senior officers fail to satisfy any debt due and payable as a judgement-debtor under any court order, during the reporting year? 4.7 Was the licensee or any of its beneficial owners, controllers, general partners, shareholders, directors or senior officers found liable in a civil suit which elicited dishonest or unlawful conduct, during the reporting year? 4.8 Was the licensee or any of its beneficial owners, controllers, general partners, shareholders, directors or senior officers, in connection with the formation, control or management of any corporate, partnership or unincorporated institution, adjudged by a court in any jurisdiction civilly liable for any fraud, malfeasance or other misconduct towards such a body or company, or towards any members thereof, during the reporting year? 4.9 Have any of the licensee's beneficial owners, controllers, general partners, shareholders, directors or senior officers been refused, restricted in or had suspended the right to carry on a trade, business or profession for which a specific licence, authorisation, approval, registration, membership or other permission is required, during the reporting year? 4.10 Have any of the licensee's beneficial owners, controllers, general partners, shareholders, directors or senior officers been found guilty of conducting any unauthorised regulated activity or been investigated for possible conduct of unauthorised regulated activity, during the reporting year? 4.11 Have any of the licensee's beneficial owners, controllers, general partners, shareholders, directors or senior officers been asked to resign or been dismissed from any fiduciary position of trust, during the reporting year? 4.12 Has any body corporate, partnership or unincorporated institution with which the licensee was associated as general partner, shareholder, director or controller, anywhere, been compulsorily wound up or made any compromise or arrangement with its creditors where they did not receive or have not yet received a full settlement of their claims, during the reporting year? 4.13 Has any body corporate, partnership or unincorporated body with which the licensee was associated as general partner, shareholder or director, anywhere, been fined or censured by any securities commission, banking commission or any similar regulatory body during the reporting year? 4.14 Is a conflicts of interest register maintained and updated for directors and senior officers? 4.15 Were any conflicts identified during the reporting year? 4.16 If the licensee has responded yes to any of the questions above, please provide full details including dates below:

9 5. GOVERNANCE (Insert responses or select applicable responses from the drop boxes as required.) Select (Yes or No) 5.1 Did the Board of Directors meet during the reporting year? 5.2 If you answered yes to 5.1 above, state how many Board of Directors Meetings were held during the reporting year. Number of Meetings 5.3 Location(s) where Board of Directors Meetings were held during the reporting year. 5.4 What was the average percentage attendance at board meetings during the reporting year? 5.5 How many executive directors does the licensee have? 5.6 How many non-executive directors does the licensee have? 5.7 Have any of the following Board Committees been Established? Committee Select (Yes or No) Audit Risk Compliance Other 5.8 If you answered yes to Other in 5.7 above, detail the name(s) of such Committee(s) below: Select (Yes or No) 5.9 Are Minutes of Board of Directors Meetings maintained? 5.10 Location where Minutes of Board of Directors Meetings are maintained. Choose Strategy Date Approved 5.11 List the business strategies, policies and/or management reports that were submitted to the Board of Directors during the reporting year and the dates that these were approved. For example, risk management strategy, institutional risk assessment methodology, strategic business plan, compliance policy, business continuity policy, outsourcing policy (if applicable), annual compliance report, financial statements, etc. 5.12 If you selected Other in 5.7 above, provide the name(s) of the other reports and the date(s) approved below: Name of other Report Date Approved

10 6. RECORD KEEPING Select (Yes or No) 6.1 Are the licensee's records adequately maintained in accordance with sections 38 and 39 of the Regulatory Code, Revised Edition 2020, and section 42 of the Anti-Money Laundering and Terrorist Financing Code of Practice, Revised Edition 2020, and in an orderly manner? 6.2 Are the records required to be maintained by the licensee readily retrievable in the Virgin Islands, in a legible form and in the English language, without delay? 6.3 Has the licensee established a record retention policy in accordance with section 39 of the Regulatory Code, Revised Edition 2020? 6.4 Are the records required to be maintained pursuant to section 96 of the BVI Business Companies Act, Revised Edition 2020, kept at the office of the registered agent? 6.5 Are the records and underlying documentation required to be maintained, kept in accordance with section 98 of the BVI Business Companies Act, Revised Edition 2020? Select (Yes, No or N/A) 6.6 Are the books and records of the companies for which the licensee provides registered agent services kept in accordance with section 102 of the BVI Business Companies Act, Revised Edition 2020?

11 7. INTERNAL AUDIT FUNCTION Select (Yes or No) 7.1 Is the licensee required to appoint an internal audit function in accordance with section 34(2) of the Regulatory Code, Revised Edition 2020? If you answered 'no' to this question, proceed to the next tab. Select (Yes or No) 7.2 If you answered yes to 7.1, has an internal audit function been appointed? Select (Yes or No) 7.3 If an internal audit function had been appointed, did such function meet the requirements specified in section 35(1) of the Regulatory Code, Revised Edition 2020? Select (Yes or No) 7.4 If an internal audit function had been appointed, did such function meet the principal responsibilities set out in section 35(2) of the Regulatory Code, Revised Edition 2020? Select (Yes or No) 7.5 If an internal audit function had been appointed, has an internal audit of the licensee been conducted during the reporting year, given the responsibilities set out in section 35(2) of the Regulatory Code, Revised Edition 2020? Select (Yes or No) 7.6 Where section 35 of the Regulatory Code, Revised Edition 2020, does not apply to a licensee that is not required to appoint an internal audit function, has the licensee undertaken such reviews of its internal controls as are appropriate for the nature, size, complexity, structure and diversity of its business? 7.7 Date last internal audit of the licensee was conducted (if applicable). Select (Yes or No) 7.8 Where deficiencies had been identified, were remedial measures implemented? Select (Yes or No) 7.9 Are the Board of Directors and senior management satisfied that identified deficiencies have been adequately addressed? 7.10 If no internal audit had been conducted during the reporting year, what is the proposed date of conducting such an audit?

12 8. BUSINESS ACTIVITIES 8.1 Types of business activities undertaken by the licensee for a company, partnership or any other legal person or legal arrangement: (Tick all activities that apply) ☐ Registered Agent ☐ Registered Office, Business Address or Accommodation, Correspondence or Administrative Address ☐ Corporate Director ☐ Arranging for another Person to act as Director ☐ Nominee Shareholder ☐ Arranging for another Person to act as Nominee Shareholder ☐ Company/Corporate Secretary ☐ Arranging for another Person to act as Secretary ☐ Partner of a Partnership/Limited Partnership ☐ Trustee of a Trust ☐ Performing the equivalent of trustee services for another form of legal arrangement ☐ Arranging for another person to act as Trustee of a Trust ☐ Arranging for another person to perform the equivalent of a trustee function for another legal arrangement ☐ Co-trustee of a Trust ☐ Protector of a Trust ☐ Administrator of a Trust ☐ Executor or Administrator - Estate of Deceased Legal Persons1 8.2 Indicate, in relation to legal persons (as applicable to the type of licence held), the services that were provided by the licensee during and up to the end of the reporting year. 8.2.1 Number of BVI Business Companies (BVIBCs) that were incorporated. 8.2.2 Number of BVIBCs for which the licensee provided registered agent services. 8.2.3 Number of BVIBCs for which the licensee provided registered office services. 8.2.4 Number of BVIBCs for which the director services were provided (i) Individual (person employed with the licensee as director) (ii) Corporate (licensee as a corporate director) (iii) Arranged for another affiliated entity or person2 , other than those mentioned in (i) and (ii) immediately above, to provide director services 8.2.5 Number of BVIBCs for which nominee shareholder services were provided: (i) Individual (person employed with the licensee as nominee shareholder) (ii) Corporate (licensee as nominee shareholder) (iii) Arranged for another affiliated entity or person, other than those mentioned in (i) and (ii) immediately above, to provide nominee shareholder services

13 8.2.6 Number of BVIBCs for which the licensee provided company secretary services: (i) Individual (person employed with the licensee as company secretary) (ii) Corporate (licensee as company secretary) (iii) Arranged for another affiliated entity or person other than those mentioned in (i) and (ii) immediately above, to provide company secretary services 8.2.7 In each case at 8.2.4 and 8.2.5, state the name of the affiliated entity and/or person and the number of such appointments each affiliated entity and/or person held at the end of the reporting year. Name of Affiliated Entity or Person Nominee Shareholder (in the VI) Nominee Shareholder (Outside the VI) Director (in the VI) Director (Outside the VI) 8.2.8 Number of BVIBCs whose business activities included acting as director. 8.2.9 Number of BVIBCs whose business activities included acting as nominee shareholder. 8.2.10 Number of BVIBCs whose business activities included acting as company secretary. 8.2.11 Number of companies that were continued into the Virgin Islands. 8.2.12 Number of BVIBCs, to which the licensee provided any of the services listed in 8.1, that formed a part of a cross-border structure3 . 8.2.13 Number of partnerships incorporated. 8.2.14 Number of partnerships for which the licensee was a partner. Legal Arrangements4 8.3 Indicate, in relation to legal arrangements (as applicable to the type of licence held), the services that were provided by the licensee during and up to the end of the reporting year. 8.3.1 Number of trusts for which the licensee was appointed as trustee during the reporting year. 8.3.2 Number of trusts for which trustee services were provided: (i) Individual (person employed with the licensee as trustee) (ii) Corporate (licensee as trustee) (iii) Arranged for another affiliated entity or person, other than those mentioned in (i) and (ii) immediately above, to act as trustee 8.3.4 Number of other legal arrangements for which the equivalent of trustee services were provided: (i) Individual (person employed with the licensee providing the equivalent service) (ii) Corporate (licensee providing the equivalent service) (iii) Arranged for another affiliated entity or person, other than those mentioned in (i) and (ii) immediately above, to provide the equivalent service 8.3.5 Number of trusts for which co-trustee services were provided: (i) Individual (person employed with the licensee as co-trustee) (ii) Corporate (licensee as co-trustee) (iii) Arranged for another affiliated entity or person, other than those mentioned in (i) and (ii) immediately above, to act as co-trustee

14 8.3.6 Number of other legal arrangements for which the equivalent of co-trustee services were provided: (i) Individual (person employed with the licensee providing the equivalent service) (ii) Corporate (licensee providing the equivalent service) (iii) Arranged for another affiliated entity or person, other than those mentioned in (i) and (ii) immediately above, to provide the equivalent service 8.3.7 Number of trusts for which protector services were provided: (i) Individual (person employed with the licensee as protector) (ii) Corporate (licensee as protector) (iii) Arranged for another affiliated entity or person, other than those mentioned in (i) and (ii) immediately above, to act as protector 8.3.8 Number of other legal arrangements for which the equivalent of protector services were provided: (i) Individual (person employed with the licensee providing the equivalent service) (ii) Corporate (licensee providing the equivalent service) (iii) Arranged for another affiliated entity or person, other than those mentioned in (i) and (ii) immediately above, to provide the equivalent service 8.3.9 Number of trusts for which the licensee provided any of the trust-related services listed in 8.1 that formed a part of a cross-border structure. 8.3.10 Number of entities for which the licensee provided executor or administrator services for an estate of a deceased person. 8.4 Indicate, in the table immediately below, how many non-Virgin Islands trusts the licensee provided the following services to: Trust Services Provided Number of Non-VI Trusts Trustee Co-Trustee Protector Administrator 8.5 Indicate, in the table immediately below, how many other non-Virgin Islands legal arrangements the licensee performed the equivalent of the listed services to: Trust Services Provided Number of other Non-VI Legal Arrangements Trustee Co-Trustee Protector Administrator 8.6 Indicate, in the table immediately below, how many non-Virgin Islands companies the licensee provided the following services to: Services Provided Number of Non-VI Companies Corporate Director Nominee Shareholder Company Secretary Partner of a Partnership

15 8.7 Indicate, in the table immediately below, how many other non-Virgin Islands legal persons the licensee performed the equivalent of the listed services to: Services Provided Number of Non-VI Legal Persons Corporate Director Nominee Shareholder Company Secretary Partner of a Partnership 1 Legal persons refer to any entities other than natural persons that can establish a permanent customer relationship with a financial institution or otherwise own property. This can include companies, bodies corporate, foundations, anstalt, partnerships or associations and other relevant similar entities. 2 Affiliated entity or person is a company within a wider group of companies or an individual employed with an affiliate. 3 Cross-border structure refers to the strategic organisation of business operations, assets and legal entities across multiple jurisdictions. 4 Legal arrangements refer to express trusts and other similar legal arrangements. Examples of other similar arrangements (for AML/CFT purposes) may include, but not limited to, fiducie, certain types of Treuhand, fideicomiso and Waqf.

16 9. MANAGING TRUST COMPANY Select (Yes or No) 9.1 Does the licensee act as a managing trust company5? 9.2 If the response to 9.1 is 'no' move on to the next tab. If the response is 'yes', complete 9.2.1 to 9.2.7 below: 9.2.1 Number of managed trust companies6 that the licensee managed during the reporting year: 9.2.2 Does the managing trust company keep the books and records of the managed trust company separate from Select (Yes or No) (i) its own books and records; (ii) the books and records of its clients; and (iii) the books and records of any other managed trust company for which it acts as a managing trust company, in accordance with section 165 of the Regulatory Code? Select (Yes or No) 9.2.3 Does the managed trust company have at least one director who is resident in the Virgin Islands? Select (Yes or No) 9.2.4 Does the managed trust company have at least one senior manager who is resident in the Virgin Islands? 9.2.5 Does the managed trust company have sufficient resources, including human and physical resources, to undertake those functions that Select (Yes or No) (i) in accordance with the Regulatory Code, cannot be outsourced; and (ii) the managing trust company is not responsible for under the Management Agreement? 9.2.6 Number of staff dedicated to carrying out the day-to-day activities of the managed trust company. Select (Yes or No) 9.2.7 Are the business and activities of the managed trust company segregated from the managing trust company’s own business and activities and from the business and activities of any other managed trust companies that it manages? Select (Yes or No) 9.2.8 Does the managing trust company maintain separate financial records and prepare separate financial statements for each managed trust company that it manages? 9.2.9 Indicate, in the table below, for each managed trust company, whether staffing resources are shared or dedicated. Name of Managed Trust Company Class of Licence Held Staff Allocation (Indicate Shared or Dedicated) 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 9.2.10 Number of BVI Business Companies for which each managed trust company provided company management services. 9.2.11 Number of trusts for which each managed trust company provided trustee services, if applicable. Select (Yes or No) 9.2.12 Did the licensee submit any reports to the beneficial owners and/or shareholders of the managed trust company during the reporting year?

17 9.2.13 If yes, state the nature of the reports: Select (Yes or No) 9.2.14 Is the licensee providing similar managing trust company services for any non-Virgin Islands entities? 9.2.15 If yes, state the name of the entity, nature of services offered, whether staff resources are shared or dedicated and the date the services commenced. (Where the licensee provided managing trust company services to more than 15 non-Virgin Islands entities, provide a separate page (labelled 9.2.15) detailing the required information.) Name of Entity Nature of Services Staff Allocation (Indicate Shared or Dedicated) Date Services Commenced 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 5 Managing trust company means the trust company that manages a managed trust company. 6 Managed trust company means a licensed trust company whose trust licence is subject to the condition that its business is carried on and managed by another licensed trust company.

18 10. PORTFOLIO MANAGED AND ADMINISTERED – LEGAL PERSONS & LEGAL ARRANGEMENTS NOTE: Items in this section refer to BVI Business Companies, partnerships, private trust companies, foreign companies and trusts in the licensee’s entire portfolio. 10.1 BVI BUSINESS COMPANIES 10.1.1 Total number of active BVI Business Companies (BVIBCs) for which the licensee provided company management services: 10.1.2 Number and percentage of active BVIBCs, for which company management services were provided, that fell within each of the following risk categories: Number Percentage Low Medium Low Medium Medium High High Critical TOTAL Number Percentage 10.1.3 Number and percentage of BVIBCs for which any of the beneficial owners were politically exposed persons. Number Percentage 10.1.4 Number and percentage of BVIBCs that had nominee shareholders. Number Percentage 10.1.5 Number and percentage of BVIBCs that had corporate directors. Number Percentage 10.1.6 Number and percentage of BVIBCs that were listed on a stock exchange. 10.1.7 Total value of assets held by the BVIBCs for which the licensee provided director services (US$): 10.2 PARTNERSHIPS 10.2.1 Total number of active partnerships for which the licensee provided company management services. 10.2.2 Number and percentage of active partnerships that fell within each of the following risk categories: Number Percentage Low Medium Low Medium Medium High High Critical TOTAL Number Percentage 10.2.3 Number and percentage of partnerships for which any of the beneficial owners were politically exposed persons. Number Percentage 10.2.4 Number and percentage of partnerships that were listed on a stock exchange. 10.2.5 Number of partnerships that formed a part of a cross-border structure. 10.2.6 Total value of assets held by the partnerships for which the licensee provided company management and/or other administrative services.

19 10.3 PRIVATE TRUST COMPANIES (only applicable to Class I Trust licensees) 10.3.1 Total number of active private trust companies (PTCs) that were administered by the licensee. 10.3.2 Total number of trusts for which the PTCs provided trustee services. 10.3.3 Number and percentage of PTCs that fell within each of the following risk categories: Number Percentage Low Medium Low Medium Medium High High Critical TOTAL Number Percentage 10.3.4 Number and percentage of PTCs for which any of the beneficial owners were politically exposed persons. Number Percentage 10.3.5 Number and percentage of all PTCs that had nominee shareholders. Number Percentage 10.3.6 Number and percentage of all PTCs that had corporate directors. Number Percentage 10.3.7 Number and percentage of trusts, for which the PTCs provided trustee services, that formed a part of a cross-border structure. 10.3.8 Total value of assets held by the trusts for which the PTCs provided trustee services (US$). 10.4 FOREIGN COMPANIES 10.4.1 Total number of foreign companies within the licensee’s portfolio. 10.4.2 Number and percentage of all foreign companies that fell within the following risk categories: Number Percentage Low Medium Low Medium Medium High High Critical TOTAL Number Percentage 10.4.3 Number and percentage of foreign companies for which any of the beneficial owners were politically exposed persons. Number Percentage 10.4.4 Number and percentage of all foreign companies that had nominee shareholders. Number Percentage 10.4.5 Number and percentage of all foreign companies that had corporate directors. Number Percentage 10.4.6 Number and percentage of all foreign companies that were listed on a stock exchange.

20 10.5 VISTA TRUSTS7 10.5.1 Total number of VISTA trusts for which the licensee provided trustee services. Number Percentage 10.5.2 Number and percentage of all VISTA trusts that were revocable. Number Percentage 10.5.3 Number and percentage of all VISTA trusts with flee clauses. Number Percentage 10.5.4 Number and percentage of all VISTA trusts that formed a part of a cross-border structure. Number Percentage 10.5.5 Number and percentage of all VISTA trusts where the settlor had reserved powers. 10.5.6 Number and percentage of all VISTA trusts, for which trustee services were provided, that fell within each of the following risk categories: Number Percentage Low Medium Low Medium Medium High High Critical TOTAL 10.5.7 Total value of assets held by VISTA trusts for which the licensee provided trustee services. 10.6 TRUSTS (NON-VISTA) 10.6.1 Total number of trusts, excluding VISTA trusts, for which the licensee provided trustee services. Number Percentage 10.6.2 Number and percentage of trusts, excluding VISTA trusts, that were revocable. Number Percentage 10.6.3 Number and percentage of trusts, excluding VISTA trusts, with flee clauses. Number Percentage 10.6.4 Number and percentage of trusts, excluding VISTA trusts, where the settlor had reserved powers. Number Percentage 10.6.5 Number and percentage of trusts, excluding VISTA trusts, that were bare trusts. Number Percentage 10.6.6 Number and percentage of trusts, excluding VISTA trusts, that formed a part of a cross-border structure. 10.6.7 Number and percentage of non-VISTA trusts, for which trustee services were provided, that fell within the following risk categories: Number Percentage Low Medium Low Medium Medium High High Critical TOTAL 10.6.8 Total value of assets held by the trusts, excluding VISTA trusts, for which the licensee provided trustee services (US$).

21 7 VISTA trusts refer to trusts established under the Virgin Islands Special Trusts Act. 11. DIRECTOR, SENIOR OFFICER, TRUSTEE, ADMINISTRATOR AND PROTECTOR APPOINTMENTS 11.1 Total number of persons employed with the licensee who performed the following duties, on behalf of the licensee, during the reporting year: a) acted as a director of a company or other body b) acted as a senior officer of a company or other body c) acted as a trustee of a trust d) acted as administrator of a trust e) acted as a protector of a trust 11.2 In each case at 11.1 above, list each individual’s name and the number of appointments that individual held as at the end of the reporting year: (These details may be submitted with this return as a separate page labelled “Item 11.2”) Director and Senior Officer Appointments Name of Individual Senior Officer Appointments Directorships (VI Entities) Directorships (Non-VI Entities) Total Directorships Trust appointments Name of Individual Trustees Administrators Protectorships

22 12. SERVICES TO REGULATED ENTITIES Select (Yes or No) 12.1 Did the licensee provide any services, up to the end of the reporting year, to any other entities that are regulated by the Commission? 12.2 If you answered yes to 12.1 above, indicate how many entities to which the licensee provided any of the following services. Type of Regulated Entity Number of Entities Approved Investment Manager Banking Company Services Provider (Company Management Licence) Financing Business Insurance Intermediary (i.e. Insurance Agents / Brokers) Insurance Manager Insurer Investment Business Money Services Business Mutual Fund Private Investment Fund Trust and Corporate Services Provider Trust Services Provider Virtual Asset Services Provider

23 13. CLIENT BASE8 Provide the following information, based on the licensee’s client base, up to the end of the reporting year. 13.1 State the number and percentage of clients that were Third-Party Clients: a. Number b. Percentage 13.2 State the number and percentage of clients that were End-User Clients: a. Number b. Percentage 13.3 State how many third-party clients, ends-user clients, settlors of trusts and beneficial owners of BVI Business Companies originated from each jurisdiction listed in the table below. LEGAL ARRAGEMENTS LEGAL PERSONS Jurisdiction Country Code Third-Party Clients End-User Clients Settlors Third-Party Clients End-User Clients Beneficial Owners Afghanistan AFG Åland Islands ALA Albania ALB Algeria DZA American Samoa ASM Andorra AND Angola AGO Anguilla AIA Antarctica ATA Antigua and Barbuda ATG Argentina ARG Armenia ARM Aruba ABW Australia AUS Austria AUT Azerbaijan AZE Bahamas (The) BHS Bahrain BHR Bangladesh BGD Barbados BRB Belarus BLR Belgium BEL Belize BLZ Benin BEN Bermuda BMU Bhutan BTN Bolivia (Plurinational State of) BOL Bonaire, Sint Eustatius and Saba BES Bosnia and Herzegovina BIH Botswana BWA Bouvet Island BVT Brazil BRA British Indian Ocean Territory (The) IOT Brunei Darussalam BRN Bulgaria BGR Burkina Faso BFA Burundi BDI Cabo Verde CPV Cambodia KHM Cameroon CMR Canada CAN Cayman Islands (The) CYM Central African Republic (The) CAF Chad TCD Chile CHL China CHN Christmas Island CXR Cocos (Keeling) Islands (The) CCK Colombia COL

24 Comoros (The) COM Congo (The Democratic Republic of the) COD Congo (The) COG Cook Islands (The) COK Costa Rica CRI Côte d'Ivoire CIV Croatia HRV Cuba CUB Curaçao CUW Cyprus CYP Czech Republic CZE Denmark DNK Djibouti DJI Dominica DMA Dominican Republic (The) DOM Ecuador ECU Egypt EGY El Salvador SLV Equatorial Guinea GNQ Eritrea ERI Estonia EST Eswatini / Kingdom of Eswatini SZ / SWZ Ethiopia ETH Falkland Islands (The) [Malvinas] FLK Faroe Islands (The) FRO Fiji FJI Finland FIN France FRA French Guiana GUF French Polynesia PYF French Southern Territories (The) ATF Gabon GAB Gambia (The) GMB Georgia GEO Germany DEU Ghana GHA Gibraltar GIB Greece GRC Greenland GRL Grenada GRD Guadeloupe GLP Guam GUM Guatemala GTM Guernsey GGY Guinea GIN Guinea-Bissau GNB Guyana GUY Haiti HTI Heard Island and McDonald Islands HMD Honduras HND Hong Kong HKG Hungary HUN Iceland ISL India IND Indonesia IDN Iran (Islamic Republic of) IRN Iraq IRQ Ireland IRL Isle of Man IMN Israel ISR Italy ITA Jamaica JAM Japan JPN Jersey JEY Jordan JOR Kazakhstan KAZ Kenya KEN Kiribati KIR Korea (The Democratic People's Republic of) PRK

25 Korea (The Republic of) KOR Kosovo (The Republic of) XKX Kuwait KWT Kyrgyzstan KGZ Lao People's Democratic Republic (The) LAO Laos LA/LAO Latvia LVA Lebanon LBN Lesotho LSO Liberia LBR Libya LBY Liechtenstein LIE Lithuania LTU Luxembourg LUX Macao MAC Macedonia (The former Yugoslav Republic of) MKD Madagascar MDG Malawi MWI Malaysia MYS Maldives MDV Mali MLI Malta MLT Marshall Islands (The) MHL Martinique MTQ Mauritania MRT Mauritius MUS Mayotte MYT Mexico MEX Micronesia (Federated States of) FSM Moldova (The Republic of) MDA Monaco MCO Mongolia MNG Montenegro MNE Montserrat MSR Morocco MAR Mozambique MOZ Myanmar MMR Namibia NAM Nauru NRU Nepal NPL Netherlands (The) NLD New Caledonia NCL New Zealand NZL Nicaragua NIC Niger (The) NER Nigeria NGA Niue NIU Norfolk Island NFK Northern Mariana Islands (The) MNP North Macedonia MKD Norway NOR Oman OMN Pakistan PAK Palau PLW Palestine, State of PSE Panama PAN Papua New Guinea PNG Paraguay PRY Peru PER Philippines (The) PHL Pitcairn Islands PCN Poland POL Portugal PRT Puerto Rico PRI Qatar QAT Réunion REU Romania ROU Russian Federation (The) RUS Rwanda RWA

26 Saint Barthélemy BLM Saint Helena, Ascension and Tristan da Cunha SHN Saint Kitts and Nevis KNA Saint Lucia LCA Saint Martin (French) MAF Saint Pierre and Miquelon SPM Saint Vincent and the Grenadines VCT Samoa WSM San Marino SMR Sao Tome and Principe STP Saudi Arabia SAU Senegal SEN Serbia SRB Seychelles SYC Sierra Leone SLE Singapore SGP Sint Maarten (Dutch) SXM Slovakia SVK Slovenia SVN Solomon Islands SLB Somalia SOM South Africa ZAF South Georgia and the South Sandwich Islands SGS South Sudan SSD Spain ESP Sri Lanka LKA Sudan (The) SDN Surinam e SUR Svalbard and Jan Mayen SJM Sweden SWE Switzerland CHE Syrian Arab Republic SYR Taiwan (Province of China) TWN Tajikistan TJK Tanzania, United Republic of TZA Thailan d THA Timor -Leste TLS Togo TG O Tokelau TKL Tonga TON Trinidad and Tobago TTO Tunisia TUN Turkey TUR Turkmenistan TKM Turks and Caicos Islands (The) TCA Tuvalu TUV Uganda UGA Ukraine UKR United Arab Emirates (The) ARE United Kingdom of Great Britain and Northern Ireland (The) GBR United States Minor Outlying Islands (The) UMI United States of America (The) USA Uruguay URY Uzbekistan UZB Vanuatu VUT Vatican City State (Holy See) VAT Venezuela (Bolivarian Republic of) VEN Vietnam VNM Virgin Islands (British) VGB Virgin Islands (United States) VIR Wallis and Futuna WLF Western Sahara ESH Yemen YEM Zambia ZMB Zimbabw e ZWE Other (Specify) TOTAL

27 13.4 Indicate how many BVI Business Companies carry on the business activities listed below. If a BVIBC carries on more than one type of business activity, mark the main activity carried on. Type of Business Activity Number of BVI Business Companies Accounting services Administrative services Advertising Aerospace industry / Aircraft services (design, development, manufacturing and maintenance) Aircraft leasing Arms and Dual-Use goods manufacturers Art (ceramics, paintings, pottery, gallery) Asset consolidation of financial products Aviation Bank Account Banking Brokerage Cannabis Car dealership Cash Intensive business Carpet industry (design, production, distribution, sale) Catering Clothing Computer hardware development Computer sales and services Computer software development Construction Consulting / Consultancy services (specify service) Courier services Cryptocurrencies Data analytics Dating / Adult entertainment Digital advertising Digital assets Digital design Engineering Export / Import (specify product) Exterminating Factory Farming Financial investment Financial management Fishing Foreign Exchange Freight brokers / Feight forwarders Furniture industry (design, manufacture, distribution, sale) Gaming / Gambling Glass fabrication Glass manufacturing Graphic design Heavy equipment / trucking Holding a vessel Holding investment portfolio Holding property Holding shares Holding shares in an entity for a trust Holding structure Insurance Interior design Internet services (website design, development, marketing, etc.) Investment (stock market) Investment (telecommunications) Investment holding (real estate, financial assets, financial markets, financial products)

28 Landscaping Laundromat Lenders Manufacturing (specify product) Marketing Meat Packing Industry Media Medical practice / medical services Mining / Oil / Gas / Resources Mobile app development Money transfer business Non-Fungible Tokens (NFTs) Online shopping Pharmaceuticals Photography / Videography Plastic manufacturing Property investment (commercial) Property investment (residential) Property management Real estate Recycling Restaurant Sailing Secretarial services Securities investment Security Ship and boat repair Shipping Solar energy / solar systems Technology Technological development Telecommunications Textiles Trading (specify) Website development Other (Specify business activity) Total 13.5 State how many BVI Business Companies form a part of a cross-border structure. 8 Client, in relation to a licensee, means a person, whether resident in or outside the Virgin Islands, to whom the licensee provides, agrees to provide or has provided a service that constitutes licensed fiduciary services business. 14. EMPLOYEES 14.1 State how many persons, inside and outside the Virgin Islands, are employed by the licensee.

29 Number of Full-time Employees in the VI Number of Part-time Employees in the VI Number of Full-time Employees Outside the VI Number of Part-time Employees Outside the VI 14.2 If applicable to the licensee, state the physical address of the licensee’s principal office outside the Virgin Islands and how many persons are employed at that location. Address of Principal Office or Principal Place of Business Outside the Virgin Islands Staff 14.3 If any person who is not an employee of the licensee, in the Virgin Islands or elsewhere, carried out regulated activities on behalf of the licensee, state how many persons carried out such activities and the physical location of those persons. Regulated Activities – Trust and Company Management Business Number of Individual(s) Location of Individual(s) Trust business activities Company management business activities 14.4 State, by position held, how many persons in the Virgin Islands joined the licensee during the reporting year. Position held Number of Staff 14.5 State, by position held, how many employees in the Virgin Islands left the licensee during the reporting year. Position held Number of Staff 15. OUTOURCING Refer to ‘Division 5 – Outsourcing’ of the Regulatory Code, Revised Edition 2020, for guidance.

30 Select (Yes or No) 15.1 Have any of the licensee’s business activities been outsourced during the reporting year? Select (Yes or No) 15.2 Has the licensee established a comprehensive outsourcing policy with respect to the activities to be outsourced, in accordance with section 52 of the Regulatory Code, Revised Edition 2020? Select (Yes or No) 15.3 Did the licensee enter into any outsourcing arrangements during the reporting year? 15.4 If any activities have been outsourced, in relation to each entity to which activities have been outsourced, state the name of the entity, the activities that have been outsourced, the volume of business activity outsourced and the jurisdiction in which that entity operates. Name of Entity Outsourced Activities Volume of Business Activities Outsourced (Percentage) Jurisdiction in which Entity Operates 16. BUSINESS CONTINUITY

31 Select (Yes or No) 16.1 Has the licensee established a business continuity policy and put business continuity arrangements in place, in accordance with section 27 of the Regulatory Code, Revised Edition 2020? Select (Yes or No) 16.2 Has the business continuity policy and arrangements been tested during the reporting year? 16.3 State the date when the business continuity policy and arrangements were last tested. Select (Yes or No) 16.4 Has the business continuity policy and arrangements been reviewed and updated during the reporting year? If yes, state the date. Date: 16.5 Did the licensee have in place reliable and secure information systems that covered all the significant activities carried on by the licensee and, where appropriate, that enabled the licensee to measure, assess and report on the size, composition and quality of its exposures, in accordance with section 31(1) of the Regulatory Code, Revised Edition 2020, during the reporting year? Select (Yes or No) Select (Yes or No) 16.6 Have the licensee’s information systems been independently monitored and supported by adequate contingency arrangements, in accordance with section 31(2) of the Regulatory Code, Revised Edition 2020, during the reporting year? 17. OTHER ISSUES Select (Yes or No) 17.1 Are there any industry and/or market-related issues which the licensee wishes to draw to the Commission's attention? 17.1.1 If yes, provide details below: 18. DECLARATION

32 DECLARATION ☐ I am authorised to complete this declaration on behalf of the licensee. I hereby certify that this return represents an accurate and fair view of the licensee's position at the above reporting period. I undertake that if other material facts are affecting the licensee's affairs which, in my judgement, should be disclosed, I will advise the Financial Services Commission. I understand that the Commission may take enforcement action against the licensee under relevant financial services legislation where false, inaccurate or misleading information is submitted within this return. Name (Last Name, First Name) Name of Organisation (if not within Licensee) Relationship to Licensee: ☐ Registered Agent ☐ Legal Representative ☐ Director/Senior Officer ☐ Employee ☐ Other (please specify): Email Address Telephone Number Date”

33 Schedule 10 amended 4. The principal Order is amended in Schedule 10 by deleting the words “[Section 9]” from the reference title and substituting the words “[Section 10]”. Made by the Financial Services Commission on this 29th day of September, 2025. (Sgd.) Kenneth Baker Managing Director/CEO Financial Services Commission