Guavaberry Media has been following the Bank of Asia saga for some two (2) plus years now. While we believe that the idea of the bank was a good one, and is in the best interest of the BVI’s financial services sector, and still can be, we also strongly believe that it is likely that the idea lost its way, in the wrong hands. BVI Airways part deux we believe.
One of the unfortunate developments that has perplexed us, is the strong hold of the Honourable Lorna Smith and her close allies on the BVI’s development, if information to us rings true; both in this saga and the BVI Airways saga.
Overwhelming bits of information flooding our newsroom post articles written by Guavaberry Media on the Bank of Asia matter, indicate that the Honourable Lorna Smith has always been a force to be reckoned with in her ability to wield power and influence.
It is alleged by persons close to the situation and in the know, that it was the Honourable Lorna Smith, in her position as then wife to the Premier of the territory, Orlando Smith, with no other public appointed authority, the one who emailed instructions that the controversial payment made to BVI Airways, be made to BVI Airways. In May 2020, following a report by the Auditor General, it was announced that there would be a 'full criminal investigation' into the Government's investment in the airline.
We are also made to understand, on the matter of the Bank of Asia, which now seems to be an affair of said Honourable Smith, that her nephew Deon Vanterpool was appointed Director after she ran for public office in 2023, technically taking her place. We understand him to have been the President of the bank in recent years and made a whopping $700 thousand per annum, roughly $58,000 per month
We list our in-depth research on the bank and its value to the financial services industry of the British Virgin Islands.
The Bank’s beginnings
1. In early 2015, the Premier of the BVI Government, Dr Orlando Smith, approached Mr Carson Wen (“Mr Wen”) with the prospects of a new, full banking licence. Mr Wen is a corporate lawyer and politician based in Hong Kong with historical ties to the BVI. He was and remains close friends with Dr Smith and Junior Minister Lorna Smith (“Mrs Smith”). Mr Wen had no previous banking experience whatsoever at the time.
2. The bank licence, if issued, was to be the first in over 20 years. The BVI then had only six (6) licenced banks, all dedicated to local business, and had (and has) zero interest in issuing any further banking licences.
3. Government intervention in the banking licence arena stemmed from the difficulties of BVI companies in securing bank accounts due to KYC-AML lapses at many of the world’s larger financial institutions and their subsequent unwillingness to deal with BVI companies. The view was then that a BVI bank willing to offer bank accounts to BVI companies without relaxing KYC-AML standards would help stabilise the BVI company product for the jurisdiction.
4. Following the development of a first business plan by Deloitte, Mr Wen brought in Mr Chad Holm (“Mr Holm”) to lead the effort. Mr Holm is a long-time financial institutions banker, having led the M&A efforts at, inter alia, Merrill Lynch and Citigroup. During that time, Mr Holm advised on some US$300 billion worth of transactions involving Blackrock, the New York Stock Exchange, JPMorgan Chase, Blackstone, KKR, Banco Santander, Société Générale, and Barclays among others.
5. After Mr Holm’s arrival and re-work of the business plan, a coordinated and intense lobbying of the BVI regulator, the BVI Financial Services Commission (the “FSC”), and the Cabinet of the Premier ensued. By this time the strategy was to develop a fully digital bank named Bank of Asia (BVI) Limited (the “Bank”) and a broader FinTech platform, with ancillary businesses (with the Bank, the “Project”) servicing the financial services needs of international clients (namely BVI companies and their UBOs).
6. In March 2016, a conditional licence was secured, with the unconditional licence granted in late March of 2017. In 2019, the licence was expanded to cover local business.
7. By late 2017, investment contracts totalling over US$135 million were executed, with the last valuing the Bank atUS$380 million and the balance of the Project at US$120 million.
8. With much fanfare, the Bank became operational in mid-2018, meaning that the values ascribed in late 2017 were based purely on its potential. That potential is even greater today, albeit it requires an effective re-start supported by substantial fresh capital and proper oversight.
The litigation – how it is a red herring for blame and how it is not
9. Mr Wen and Mr Holm fell out in mid-2016 after Mr Wen failed to deliver (i) a material equity stake (22%); and (ii) nearly US$1 million in past-due compensation to Mr Holm. They parted ways shortly thereafter, with Mr Wen left without the individual who devised the business strategy and who was instrumental in getting the conditional licence (see below).
10. In January 2017, following multiple attempts to dispose of the dispute, Mr Holm was left no choice but to file a claim in BVI against Mr Wen, his wife, and their corporate vehicle holding the interest in Bank of Asia, Sancus Financial Holding Limited (“Sancus Financial”) for breach of contract. The trial was split between liability and quantum in June 2018.
11. In December 2018, the BVI Commercial Court handed down judgment on liability in favour of Mr Holm, stating that “[q]uite frankly, I had very little difficulty in finding Mr Wen and Ms Fung liable for breach of the BVI Contract on a balance of probability.” The Judge also found Mr Holm to be “a thoroughly believable and knowledgeable witness” and “an impressive witness…not fazed in any material way by cross examination so as to place in doubt his evidence which was entirely consistent with his pleadings, witness statements, and e-mail trail.” No such findings were made in favour of Mr Wen and his wife.
https://www.eccourts.org/judgment/chad-holm-et-al-v-sancus-financial-holdings-limited-et-al
12. Shortly following the first instance judgment, investors speaking for US$70 million of the US$135 million mentioned above terminated their binding contracts. There was evidence from Mr Wen at the liability trial that a separate party was prepared to invest “very large numbers”, but that party failed to invest as well. At the time, the Project had spent all but US$25 million or so of its raised capital. Plainly, it had built an infrastructure dependent on acontinuous flow of substantial investment capital. The findings against Mr Wen brought that prospect to a screeching halt.
13. Importantly, the first instance judge had ordered that the quantum trial be held in February 2020. This would have concluded the litigation, and the business could then have moved on without the black cloud of a dispute.
14. For reasons unknown, instead of moving to conclude the litigation as quickly as possible, the Defendants doubled down in deciding to appeal the liability judgment, with the Court of Appeal dismissing the appeal in March 2020. The Court of Appeal described the first instance judgment as “unimpeachable”, whilst referring to the “inconsistencies” in the evidence adduced by Mr Wen and his wife.
15. The Court of Appeal judgment went on further to state the following, most certainly not a favourable finding for Mr Wen in so far as prospective investors are concerned: “[t]his was an ambitious commercial endeavour which required, not only legal expertise, but finance and banking acumen. The evidence showed that Mr. Wen accepted that Mr. Holm had the necessary acumen and he did not. At the time Mr. Wen had not only been unable to raise the necessary capital, which continued for several months and was the impetus for the conflict between himself and Mr. Holm, but his initial application for a banking licence had been rejected by the FSC because of shortcomings in its strategy outline. Mr. Holm was able to fill in these gaps.”
https://www.eccourts.org/judgment/sancus-financial-holdings-limited-et-al-v-chad-holm-et-al
16. Clearly not getting the message as to their liability and misconduct more generally, and the adverse impact prolonging the litigation was having on business, the Defendants wasted a further nearly three years in their appeal to Privy Council. In June 2022, the Privy Council dismissed the further appeal after only 30 minutes, with the written judgment delivered in November 2022. By this time, there were still no efforts made by Mr Wen to entertain further efforts by Mr Holm to settle the matter (through without prejudice correspondence).
https://jcpc.uk/uploads/jcpc_2020_0085_judgment_84e7b998be.pdf
17. Separate and apart from the matter of liability, the Defendants were twice found by the BVI Commercial Court to have dissipated material assets and to be a real risk to dissipate their assets further (2019 and 2023). In each instance the finding of dissipation was upheld by the Court of Appeal (2019 and 2025). The latest judgment described Mr Wen as “dishonest”.
https://www.eccourts.org/judgment/sancus-financial-holdings-limited-et-al-v-chad-christopher-holm
18. Lastly, is the matter of Defendant insolvency. Mr Holm brought applications to appoint liquidators/trustees over the three Defendants on the basis of unpaid debts due to him. Sancus Financial was declared (cash-flow) insolvent in July 2024. Mr Wen and his wife were declared bankrupt in January 2025. In reality, this should have had no economic effect on the Bank; the Defendants were already subject to a freezing injunction and therefore should not have been funding the Bank and/or its affiliates in any way.
2019 to Current – a grossly-undercapitalised Bank with Mr Wen repeatedly doubling down
19. Despite the initial positive buzz around the Bank and its clear potential, the reality is that its capital position since the first instance liability judgment was handed down in December 2018 has been wholly insufficient to allow it to ever begin to achieve its ambitions.
20. This dynamic has plainly been caused by Mr Wen, though the damage could easily have been mitigated had hopeless appeals not been pursued and blatant asset dissipation not having occurred. Why someone close to the situation with a rational head did not step in and curtail Mr Wen’s reckless and plainly selfish acts, remain a mystery.
21. With Mr Wen’s reputation and credibility in tatters, it is fanciful to believe that a sophisticated investor was ever going to place substantial capital in a business with him at the helm or involved at all (and none did).
22. Even Mr Wen’s own solicitors acknowledged this in stating by way of correspondence in mid-2021 that “potential investors have been put off by the litigation”. By this stage the entire dispute would have been over had Mr Wen stopped appealing “unimpeachable” judgments. And yet Mr Wen’s behaviours became even more troubling thereafter.
23. The liability findings problems were compounded by Mr Wen breaching court orders at every opportunity, and then bringing the freezing injunction (WFO) matter into the spotlight by appealing a clear-cut, private ex tempore first instance judgment. As it were, in March 2025, the Court of Appeal handed down a 65-page public judgment dismissing the appeal, with extensive references to the first instance ex tempore judgment (that would never have seen the light of day but for the appeal), whilst referring to Mr Wen as “dishonest”. Among others, Offshore Alert picked up on the judgment and wrote a fairly extensive article shortly thereafter.
24. As to business operations, it should hardly be surprising in circumstances of there being no meaningful capital that the following occurred. Whilst the market may now chalk up the current precarious state of the Bank to poor execution or a failed business strategy, the reality is something starkly different – it never had the bare bones of capital to execute a great strategy due to the selfish actions of Mr Wen and the complicity of others. In short:
(a) no credit function was ever developed, so there was no means to make money on deposited sums through lending (net interest income);
(b) the key income earning ancillary businesses, such as investment management, brokerage, etc., were mothballed due to a lack of capital and qualified personnel;
(c) mission critical technology re-investment was curtailed, with the natural consequence being a digital bank whose technology was poor to put it mildly, leading to serious customer dissatisfaction;
(d) correspondent banking relationships were difficult to secure and maintain given the lack of capital and any meaningful business to provide to the correspondent banks;
(e) no steps could be taken to capture the evolving digital asset opportunity unique to BVI, including securing a virtual asset service provider (VASP) licence, all of which require meaningful capital and qualified personnel;
(f) business marketing came to a standstill; and
(g) understandably, key staff departed over time and there were no funds to replace them.
Accounting gimmickry in the hopes of a deal
25. Beginning in mid-2019, the Bank started having its affiliate company in Hong Kong withhold invoicing it for services. No expense or liability was recorded on the Bank’s books, naturally leaving equity capital at a sufficient level (for the time being). Through credible sources, this figure amounts to a staggering US$15 million or so. True or untrue, Mr Wen has claimed that he was instead paying for the services rendered out of his own pocket (likely in breach of the WFO, if true). However, neither Mr Wen’s nor his wife’s statement of affairs in their bankruptcies suggest a debt is owed to either by the affiliate (so the debt might have been written off). This may well explain the reason why the Bank did not or could not produce audited financial statements (if that is true).
26. Then, starting in 2022, and much more troubling, the Bank began to engage in some very questionable accounting gimmickry to boost its capital ratios: take third party customer deposits and use them to make loans to shell companies owned by Mr Wen and his friends who would then immediately return the vast majority to the Bank in the form of preferred equity redeemable at par. The reality, however, is that the only means for the shell company borrowers to repay these ‘loans’, totaling a little less than US$10 million, was a Bank sale, with the proceeds used to redeem the preferred equity. The material loans-to-equity transactions above occurred whilst Mrs Smith was the Bank’s Chairman. Whether they continued thereafter is unknown, but in any case with such a limited loan book the Chairman would have been intimately familiar with its details.
Previous sale efforts all initiated by Mr Wen
27. The strategic (future, with capital) value of the Bank has been well-recognised by the marketplace, as multiple US$400 million sale term sheets and one binding agreement were executed between 2021 and 2024, with each also reflecting a very substantial primary capital investment (up to US$1.0 billion in one case).
(a) However, all of these were sourced by Mr Wen and countersigned by a syndicator.
(b) All but one was executed with a China-connected investor/buyer, the only market Mr Wen is intimately familiar. No proper steps were ever taken to fish in a different pond.
(c) It should come as no surprise that upon initiating the syndication process, the potential investors did their due diligence and learned of Mr Wen’s legal troubles and his increasingly troubled reputation from public documents.
(d) Since no one seemed willing to push Mr Wen to the side in the best interests of the business (and he most certainly would not step away), and it was him that had the relationships with the syndicators, it is hardly surprising that none of the transactions completed.
28. What is abundantly clear given the persisting inadequate capital state is that the Bank was always in a holding patternthough attempting to portray itself otherwise. It was and remains a fantastic untapped opportunity, which has only become stronger with the BVI’s friendliness to the emerging digital asset space, but which can never thrive without access to substantial capital. As history has shown, no material capital (or in fact any capital at all) has been available with Mr Wen anywhere close to the business.
29. Now one might ask, why didn’t Mr Wen lower the (agreed) price from US$400 million? Notwithstanding his evidence that this is what the ‘market’ was willing to pay (though this did not prove out), the answer is likely two-fold: (i) the damages likely due to Mr Holm demanded a price of this sort so that Mr Wen could financially benefit after settling the debt; and (ii) when operator credibility is the issue, particularly in a business with trust and confidence at its core, it is unclear whether an investor will invest at any price.
30. But what can unequivocally be said about the (in)actions on the part of the Government and the FSC to-date is that each believed that a major transaction would come along and solve all problems. To put it bluntly, turning a blind-eye or in fact being complicit in what might arguably amount to serious wrongdoings, was the means to an end. Plainly, the Virgin Islands Deposit Insurance Corporation (“VIDIC”) took a different view or simply could not wait any longer. What all involved failed entirely to understand is what should now be clear: a grossly tainted Mr Wen leading the sales effort, fishing in his small pond, was never going to result in a major deal (or any deal at all).
31. As it were, after nearly 8 years of litigation prolonged by appeals upon appeals by Mr Wen, it became obvious that the only way to separate Mr Wen from the business and open the pathway to strategic capital unaffiliated with him was to have him and his corporate vehicle declared insolvent/bankrupt. It should be noted that Mr Wen claims to have been drawing a salary of US$800,000 per year at all material times.
2025 – Preparing for a sale and the provisional liquidation order
32. 2025 should have been the opportune time to begin the re-set of the Bank in its entirety, finally placing it in the hands of well-capitalised investors and a respected leadership team capable of executing on the evolving strategic opportunity. Unfortunately, the board of the Bank refused to deal with the joint liquidators to Sancus Financial (in place since July 2024), which is shocking in itself. Breach of fiduciary duties aside, what plan the board of the Bank might have had (if any) to solve the problem without the assistance of competent officers of the court controlling no less than 44% of the Bank is unknown; but it plainly did not work.
33. Then, with no advanced warning, on 28 May 2025, VIDIC filed an ex parte application to place the Bank in provisional liquidation. The petition evidencing the basis for the application is under seal (for now), but it should hardly be surprising that the answer lies in the Bank’s tenuous capital position, probably exacerbated by the deposits to loans to preferred equity manoeuvrings. VIDIC’s task is to protect depositors and appears less concerned with the broader implications of its actions. Sources have suggested that the Government and the FSC were, and remain, opposed to the (arguably) extreme step taken by VIDIC, presumably taking a longer-term view that a sale was possible/probable. Whether any of these stakeholders were aware of strong interest being represented by the joint liquidators to Sancus Financial is unknown. It would be surprising to learn that VIDIC was aware.
34. As for the US$5 million deposit made some time in 2025 by the Government, the circumstances and rationale are currently a mystery. Was this simply incompetence, or was there a coordinated effort to prop up the Bank’s equity capital through the same deposit to loan to a friend to preferred accounting trickery? If this is the case, the Government has a whole lot more to answer for than just an ill-advised deposit and the loss of some funds if the Bank goes under. Either way, the timeline should not be lost on anyone:
(a) January 2025: Mr Wen and his wife were declared bankrupt in open court.
(b) February 2025: the current Premier, Mrs Smith, and Mr Penn travelled to Hong Kong. It is believed that (at a minimum) Mrs Smith met with Mr Wen on the trip. Her speech on 11 March 2025 is credible evidence to support this – meeting with long-time friends and BVI supporters etc. Plainly, that must include her long-time friend and then bankrupt Mr Wen. So, what was discussed between them, e.g., a US$5 million capital injection? Was the Premier in the room?
(c) Late March 2025: the WFO appeal judgment is handed down.
Uniqueness of the Bank opportunity
35. BVI is home to roughly 400,000 incorporated companies, and therefore a sizeable captive audience. There should be no doubt that with capable management and proper governance, meaningful capital, and cutting-edge technology, material deposits and other investment funds will flow to the Bank and its affiliates.
36. The Bank is the only bank in the BVI capable of servicing the international market. Recent reports suggest that over US$1.4 trillion in assets are currently held by BVI companies (or rather pass through BVI entities on an annual basis).
https://www.ifcreview.com/articles/2024/september/british-virgin-islands-a-super-connector-to-global-markets/
37. The licence affords the Bank an ability to have the vast majority of its staff outside of BVI, with only a requirement that a majority of the board be resident and a majority of the most senior executives be resident (the ‘mind and management’ requirement). This is easily managed, and makes the Bank less reliant on more limited (though high quality) local talent.
38. The FSC has arguably become one of the friendliest regulators towards the digital asset space, and has made great strides towards helping develop various products to address this key market. Much of the jurisdiction’s marketing emphasis today is on FinTech and the BVI’s unique position in this regard. A FinTech Summit is to be held 25 to 27 June 2025 on Necker Island.
https://fintechontheseas.com
39. Arguably, to fully capitalise on its FinTech ambitions the BVI needs a licenced bank dedicated to this effort (or one at least addressing it in some form) – a hub to which the entrepreneurial venture spokes can attach. No one would dispute that the Bank is the only institution in the BVI that can do this.
40. Strong relationships with corporate service providers remain, though they need to be given quality financial services products (unlike in the past).
41. The Government and the FSC appear to remain supportive of this unique endeavour, provided a well-capitalised investor and a proper management/board comes onto the scene very quickly. In fact, with a positive solution now, these bodies should be even more willing to facilitate the success story (without the FSC relaxing any standards).
The current reality – what is and what is not being invested in?
42. A truly scarce financial asset, with strong government backing in a highly attractive offshore jurisdiction committed to being on the forefront of the digital asset evolution.
43. However, it should be assumed that:
(a) the provisional liquidation status will cause the limited deposit base to withdraw their funds at the first opportunity (at least temporarily);
(b) the existing technology has been under-invested in and needs to be materially upgraded or replaced;
(c) the small loan book is effectively worthless (though the preferred equity can likely be redeemed for nil); and
(d) the remaining staff is depleted to a minimum and will need to be greatly enhanced.
44. In effect, what is being invested in relates wholly to the Project’s potential, save for having in place an infrastructure of two licences (including an investment/deal licence), a business plan and all of the necessary policies and procedures approved by the FSC, and the relationships that have been cultivated.
45. On the positive side, the equity capital shortfall can be identified, is quantifiable, and is not particularly large – a small non-performing loan book tied to the preferred equity, potentially a liability to an affiliate, and quite limited breakage costs. This is not a situation where there is some massive loan book that is non-performing (ala those duringthe financial crisis).
46. Crucially, the fundamental reason for the Bank not beginning to achieve its potential (capital provided) should now be gone.
47. No one should be under any illusion that the valuation potentially achievable following Mr Wen’s exit and in an orderly process pre-provisional liquidation announcement is achievable today. Equally, no one should be under an illusion that the FSC will issue a new bank licence in this lifetime.
48. Meaningful, albeit discounted value should most certainly remain, provided that:
(a) time is afforded for everyone to step back from the noise and let rational behaviour take over;
(b) a scarce BVI bank licence is of strategic value, which it plainly should be;
(c) one accepts that the reasons for the Bank’s and the broader Project’s lack of success to-date are a function of the lack of capital secured as a result of Mr Wen and his wrongdoings, and the complicity of others;
(d) multiple proper protections can be put in place, including a team on the ground to work with the regulators and the Government for a smooth transition;
(e) an impeccable longer-term day-to-day and oversight team can be put in place; and
(f) a sensible deal structure can be agreed in fairly short order.
A sale – if the process can be slowed down – versus the alternative of a failed bank
49. Depositors and creditors are made whole. It is fairly certain that the alternative will result in (substantial) losses to the uninsured and may (if the problem is big enough) result in losses to VIDIC’s fund.
50. Government is returned its US$5 million (with interest), though an enquiry may still be in order to ensure a similar event does not occur in the future.
51. VIDIC (and the FSC), who care about stability and governance, can claim its actions facilitated a positive private sector solution, with that solution saving material liquidation-related costs and time and effort expended by numerous parties on tangential matters.
52. There is a compelling argument that VIDIC may well have unknowingly jumped the gun with its application to appoint a provisional liquidator.
(a) The Virgin Islands Deposit Insurance Act 2016 (amended in 2023) in effect states at section 17A(3)(g) and (k) under the title “Resolution of Failing Insured Institution” that a determination of ‘fail’ or ‘likely to fail’ is only to be made once it is concluded that there is no reasonable prospect of a private sector solution.
“The grounds for appointing a conservator or receiver, which may be [VIDIC] for any relevant person are as follows:…(g) Losses – The relevant person has incurred or is likely to incur losses that will deplete all or substantially all of its capital, and there is no reasonable prospect for the relevant person to become adequately capitalised as required by the [FSC]…(k) Undercapitalisation – The relevant person is undercapitalised and (i) has no reasonable prospect of becoming adequately capitalised in accordance with the [Bank and Trust Companies Act]…” (emphasis added).
(b) See also paragraph 107(1)(c) of the Virgin Islands Deposit Insurance Corporation Regulations, 2023 titled “Grounds for Appointing the Corporation Receiver” for similar language.
“[VIDIC] shall act as receiver or liquidator and exercise its powers whenever [VIDIC] forms the opinion in relation to the relevant person that the relevant person is in the following circumstances:…(c) the relevant person is failing or likely to fail and there is no reasonable prospect for a private sector solution to its failing or likely to fail condition”(emphasis added).
(c) There have clearly been prospects of a “reasonable private sector solution” going back for many, many months, but those have been ignored by the board of the Bank, and it is likely that VIDIC was unaware of these solutions else it is unlikely to have brought forward the application before first investigating the matter.
53. Criticisms of the FSC should fall by the wayside, which is not only good for the FSC but for the jurisdiction as a whole. Internal remedial actions can be taken in due course.
54. FinTech and Crypto champions (including entrepreneurs, the FSC, and BVI Finance) will plainly cheer.
55. The local and international investment community will take note that maybe things are now turning for the better. Absent a positive solution, there will be serious questions asked by existing and prospective investors about the BVI as a jurisdiction to place any capital going forward.
56. Local job creation is a given. How material this will be is dependent on the size of the capital investment and the scope of the reinvigorated operation.
57. It deflects from the ‘grey’ list status and the public register debate, particularly if a strategic shift in the business makes the jurisdiction less dependent on incorporated companies for revenue.
58. Whether for the better or worse, it potentially cuts off UK involvement in this matter, and whatever consequences that may bring.
59. It most certainly curtails or eliminates satellite litigation against, inter alia, directors, senior employees, affiliates of the bank, and others. That litigation could go on for years and years, and would undoubtedly be very public and leave the jurisdiction with a further black eye.
60. Most certainly the BVI’s banking sector (or more appropriately, its financial services offering) is anything but stable right now. A positive solution will begin to right the ship.
61. Again, for better or worse, the reputations of numerous individuals are likely to be stabilised.
62. The end script should read: great strategic opportunity, but bad people that acted in their own self-interests for years never instilled trust and scared everyone away, including depositors and investors. Now, a new day has come to turn the page.
63. The cost to try in circumstances where the assets have already been ring-fenced and there is little to no prospect of any deterioration of the assets in the interim are limited:
(a) A short amount of time to try to properly market the future opportunity without the overhang of Mr Wen and his associates being involved.
(b) The time to convince the FSC in particular that a new business plan is viable and new leadership is capable. Hopefully the FSC will be realistic regarding the time this will take.
64. The alternative, a failed bank, may well be catastrophic for the BVI.
(a) The impact on its financial services reputation, including the trust and confidence in its regulators, and the economy as a whole, could be incalculable. This at a time when the jurisdiction can ill-afford it.
(b) Equally, what will inevitably come will be embarrassing to say the least, and attempts to lay all blame at the feet of Mr Wen will fail. There appear to be too many parties directly involved or complicit in what has occurred since the beginning of 2019.
(c) The COI may pale in comparison to what lies ahead. Allowing certain people to potentially escape public persecution is a small price to pay in the circumstances.
65. If there was ever a time to put differences to the side and for all parties to work constructively for the good of the jurisdiction, it is now. There is little cost to doing so.
66. It is not an exaggeration to convincingly contend that the fate of the BVI, and not just its financial services sector, is now at stake.