UK modifies the Overseas Territories sanctions in respect of Iran
On 13 December 2023, the United Kingdom issued an Order revising and amending the regime relating to Iran.
Iran Sanctions Order (the Iran Order) reissues the UK’s sanctions regime on Iran for human rights abuses. The Iran Order:
- extends and modifies the Iran (Sanctions) Regulations 2023 to the British Overseas Territories (excluding Bermuda and Gibraltar) and implements sanctions for designated individuals involved in certain activities
- include financial sanctions, trade restrictions on specified goods and technology related to Iran and a prohibition on providing interception and monitoring services to the Iranian government
- creates certain exceptions for certain situations
- allows the Governor of the respective Overseas Territory to issue licences for prohibited activities with the consent of the UK’s Secretary of State
- mandates the publication of an updated list of designated persons, prescribes enforcement powers and establishes criminal offences and penalties for violating the sanctions
- allows for specific provisions of Part 1 of the Sanctions Anti-Money Laundering Act to be extended to the Overseas Territories; and
- revokes the Iran (Sanctions) (Overseas Territories) Order 2020 and came into force on 14 December 2023
A copy of the Iran Order can be found here.
The Overseas Territories affected by these updates include Anguilla, the British Virgin Islands, and the Cayman Islands. In practice, Bermuda tends to publish legislation that is equivalent to the UK in its domestic sanctions regime.