On 4 October 2022, the Cayman Islands issued General Licence GL/2022/0001 (the General Licence) under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 as extended to the Cayman Islands (with modifications) by the Russia (Sanctions) (Overseas Territories) Order 2020.
The General Licence allows a Relevant Investment Fund or Fund Manager to redeem, withdraw or otherwise deal with an Investment Interest and make payments for basic needs, routing holding and maintenance and legal fees from frozen accounts.
No funds or economic resources must be made available directly or indirectly to, or for the benefit of, a Designated Person or any Person which is owned or controlled directly or indirectly by a Designated Person.
A Designated Person is any person (whether an individual or a corporate person) who has been designated by the United Kingdom Secretary of State.
As outlined in the General Licence, a Relevant Investment Fund or Fund Manager that is regulated by the Cayman Islands Monetary Authority (CIMA) must notify CIMA, of its use of this licence within three (3) business days of such use.
Any Relevant Investment Fund or Fund Manager which is conducting activities or making payments in accordance with the General Licence must keep accurate, complete and readable records of any such activity for a minimum of six years.
Should you have any queries regarding the General Licence, or any other sanctions matter, please reach out to the authors.