An understanding of these changes are important for businesses based in the UKOTs to ensure they remain compliant and avoiding regulatory issues. The Order ensures that sanctions regimes in the UKOTs remain aligned with developments under UK domestic legislation.

The Order updates various existing sanctions orders to reflect recent changes made to UK sanctions regimes under the Sanctions and Anti-Money Laundering Act 2018. Specifically, it implements the modifications introduced by the Sanctions (EU Exit) (Miscellaneous Amendments) (No. 2) Regulations 2024 in the UKOTs.

1. Multiple sanctions regimes updated

The Order introduces tailored updates across a wide range of UK/UKOT sanctions regimes, including those targeting Venezuela, North Korea, Russia, Iran, Syria, and global anti-corruption measures. These amendments are designed to close gaps and ensure consistency.

2. Better information sharing

One of the main themes is enhanced financial transparency. New provisions allow relevant public authorities in the UKOTs to share information with the Governor or an authorised officer. This strengthens the information-sharing framework needed for effective sanctions enforcement.

3. Paying statutory obligations whilst under sanctions

The Order clarifies how "required payments" work. It creates explicit exceptions to asset-freeze rules for payments that a designated person must make under UKOT law.

This covers payments to:

• Government departments
• Customs and revenue authorities
• Company registrars
• Financial regulators
• Land authorities
• Consolidated funds

Importantly, the amendments also allow a designated person to reimburse a non-designated person who has made such a payment on their behalf. This practical change ensures that routine legal obligations can be met without accidentally breaching asset-freeze rules.

4. Keeping up with the modern economy: cryptoassets and art

The Order significantly expands the definition of "relevant firm" across numerous sanctions schedules to reflect modern business realities.

The updated definition now includes:

• Cryptoasset exchange providers – firms that exchange cryptoassets for money or other cryptoassets
• Custodian wallet providers – firms that safeguard cryptoassets or private cryptographic keys for customers
• Art market participants – firms trading in or acting as intermediaries for art sales worth €10,000 or more
• Insolvency practitioners – persons administering insolvency proceedings
• Letting agents – firms carrying out letting agency work

Reporting to the Governor

Amendments have been made to direct reporting obligations towards the Governor rather than the Treasury in specific contexts. This streamlines the administrative process and clarifies who is responsible for oversight in the UKOTs.

Insolvency proceedings

The Order clarifies the rules around insolvency. It sets out specific conditions under which actions related to insolvency and restructuring proceedings involving a designated person can occur. The key safeguard remains: any payments made directly or indirectly to a designated person must be credited to a frozen account.

This Order ensures that UKOTs maintain consistency with the UK's evolving sanctions framework, reinforcing the global effort to address issues like terrorism, corruption, and human rights abuses.

What should firms do next?

Given the expansion of relevant firm definitions and adjusted reporting lines, organisations with activities or structures in the OTs should review their sanctions screening and reporting processes. If you need support or guidance in navigating these changes, our team is available to assist.

Sanctions (Miscellaneous Amendments) (Overseas Territories) Order 2025 can be accessed here.