Parliament has, on an ongoing basis, issued its views on compliance with these requirements in Briefing Papers issued by the House of Commons, the most recent dated 31 October 2025. This details the application of UK sanctions against Russia within the UK's 14 Overseas Territories (OTs). It also evaluates the progress toward implementing public registers of beneficial ownership, but that is for another blog.

This review offers essential insights into the legal framework and practical challenges of enforcing international sanctions and promoting financial transparency across the OTs. In this blog we focus on the OTs which we advise on: Anguilla, Bermuda, the British Virgin Islands and the Cayman Islands.

Sanctions framework in the OTs

The paper confirms what every OT sanctions lawyer already knows, that the primary legal instrument governing UK sanctions is SAMLA. That UK Government policy mandates that any sanctions regime, including the Russia (Sanctions) (EU Exit) Regulations 2019, must be given effect in the OTs – which is formally extended through Orders in Council, such as the Russia (Sanctions) (Overseas Territories) Order 2020. Consequently, OTs are legally required to apply the same sanctions as the UK.

The document highlights several key findings and legislative actions:

• The full extent of Russian assets located within the OTs remains largely unknown. However, significant actions have been taken.
• As of 2024, the UK and OT governments reported that a total of £7 billion in accounts and assets had been frozen since 2022.
• In February 2022, Transparency International UK identified approximately £830 million worth of property in the OTs and Crown Dependencies linked to individuals close to the Russian President or those accused of corruption.
• A November 2024 analysis suggested significant exports from OTs to Russia, valued at US$134 million in that year.

For more information, the House of Commons research briefing can be accessed here