The United Kingdom, through Statutory Instrument, has ordered certain British Overseas Territories to observe and implement existing United Nations, United Kingdom and European Union Sanctions Orders, including all economic sanctions of record.
There are 27 countries, and two designated terrorist organizations, listed on the document, including Venezuela and Lebanon, and those sanctions orders should be reviewed by compliance officers located in those Overseas Territories named therein, which are the Cayman Islands, the British Virgin Islands, Anguilla, the Turks & Caicos Islands, and a number of minor possessions. Bermuda is notably absent from the Order.
Should sanctioned individuals and entities be encountered, there is a reporting requirement; it is understood to be the local regulatory agency. in addition to the financial industry, the Order applies to casinos, auditors, external accountants, legal professionals, real estate agents, and trust or company service providers, among others.
The effect of this order is that it imposes additional obligations upon compliance officers working in the above-listed jurisdictions. Failure to report constitutes an offense carrying a three month jail sentence, or a fine of £5000. Readers who wish to review the complete document may access it here.