Regulatory

Blog

Regulatory

Contributors

Aki Corsoni-Husain
Aki Corsoni-Husain
  • Aki Corsoni-Husain

  • Partner
  • Cyprus
George Apostolou
George Apostolou
  • George Apostolou

  • Partner
  • Cyprus
Chiara Deceglie
Chiara Deceglie
  • Chiara Deceglie

  • Partner
  • Luxembourg
Massimiliano della Zonca
Massimiliano della Zonca
  • Massimiliano della Zonca

  • Senior Associate
  • Luxembourg
Philip Graham
Philip Graham
  • Philip Graham

  • Partner
  • British Virgin Islands
Ayana Hull
Ayana Hull
  • Ayana Hull

  • Counsel
  • British Virgin Islands
Katerina Katsiami
Katerina Katsiami
  • Katerina Katsiami

  • Associate
  • Cyprus
Petros Kiteos
Petros Kiteos
  • Petros Kiteos

  • Associate
  • Cyprus
Andrew Knight
Andrew Knight
  • Andrew Knight

  • Partner
  • Luxembourg
Joshua Mangeot
Joshua Mangeot
  • Joshua Mangeot

  • Counsel
  • British Virgin Islands
Mirza Manraj
Mirza Manraj
  • Mirza Manraj

  • Counsel
  • Hong Kong
Elina Mantrali
Mirza Manraj
  • Elina Mantrali

  • Associate
  • Cyprus
Vanessa Molloy
Vanessa Molloy
  • Vanessa Molloy

  • Partner
  • Luxembourg
Andrea Moundi Savvides
Andrea Moundi Savvides
  • Andrea Moundi Savvides

  • Consultant
  • Cyprus
Marina Stavrou
Marina Stavrou
  • Marina Stavrou

  • Associate
  • Cyprus
Matt Taber
Matt Taber
  • Matt Taber

  • Partner
  • Cayman Islands
Carolynn Vivian
Carolynn Vivian
  • Carolynn Vivian

  • Senior Associate
  • Cayman Islands

British Overseas Territories sanctions update

Further to our previous post on the Overseas Territories sanctions regime that can be found here, we would highlight The Somalia (Sanctions) (Overseas Territories) (Amendment) Order 2020 (the Order) that was made on 11 March 2020, laid before Parliament on 18 March 2020 and came into force on 8 April 2020.

The Order amends the Somalia (Sanctions) (Overseas Territories) Order 2012 which gives effect in all Overseas Territories including Anguilla, the British Virgin Islands and the Cayman Islands to the sanctions regime established by the United Nations Security Council in respect of Somalia.

The Order gives effect to the amendments to the sanctions regime made by resolution 2498 (2019) which was adopted by the United Nations Security Council on 15 November 2019. It establishes a prohibition on the sale, supply, transfer or export of certain components for improvised explosive devices and makes amendments to the related licensing and enforcement provisions. It also amends the article (article 10) which provides for the Governor of a Territory to licence certain activities in line with the updated exemptions and derogations relating to the arms embargo as provided for in resolution 2498 (2019).  The Order reflects the implementation of those provisions by the European Union in Council Decision (CFSP) 2020/170 of 6 February 2020 and Council Regulation (EU) 2020/169 of the same date, which amends the provisions of Council Regulation (EC) No 147/2003 respectively.

A copy of the Order can be found here.

*This note covers Anguilla, British Virgin Islands and the Cayman Islands. Bermuda implements its own sanctions regime. For more information on the Bermuda sanctions regime, please see here.

Service providers in the financial services industry are encouraged to regularly review the client due diligence held to determine if any clients may be subjected to any Overseas Territories sanctions. A list of the financial sanctions targets can be found here. If any client is subject to sanctions, the relevant corporate services provider should liaise immediately with the relevant reporting officer and the competent authority in the Overseas Territory and seek legal assistance where applicable.