Sanctions Regimes

The Cayman Islands Sanctions Regime

The sanctions in force in the Cayman Islands are essentially the same as those imposed in the United Kingdom (“UK”).  It is the UK’s Government policy to ensure that the Overseas Territories (“OTs”) are legally and practically enabled to implement the sanctions adopted by the UN and sanctions regimes established in the UK, in order to ensure compliance with the UK’s International obligations and promote the UK policy objectives.  The Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”) provides the legal framework for the UK to impose, update and lift sanctions autonomously.  Regulations made under SAMLA can be found on legislation.gov.uk. The measures contained in the Regulations are not directly applicable in the OTs so an implementing Order in Council (“Order”) is drafted by the Foreign, Commonwealth & Development Office (“FCDO”) Legal Directorate, to be made by The King in Council (the Privy Council), which extends the regime to the OTs with or without modifications to ensure it can be effectively implemented in the OTs. Once extended to the Cayman Islands, these Orders have the force of law in the jurisdiction and breaches may constitute an offence for which fines and/or criminal convictions may result, as such sanctions will apply to everyone in the Cayman Islands.  Thus all designations made under the UN and the UK sanctions measures have immediate effect in the Cayman Islands once the Orders come into force.

The below list represents the current sanctions regimes in force in the Cayman Islands. It is necessary to read the Orders in conjunction with the sanctions regulations, which can be found here.  The UK financial sanctions targets by regime, which lists all financial sanctions imposed in the UK by country, administration or terrorist group, can be found here.

There are currently 34 sanctions regimes in force the Cayman Islands which include financial sanctions measures. Some of these regimes include other sanction measures such as trade and travel bans.   There are 2* sanctions regimes with no financial sanctions measures, but which impose trade restrictions on military goods and technology in relation to Lebanon and trade restrictions in the Syrian cultural property.

The Financial Reporting Authority (FRA) does not guarantee this list to be accurate, complete and up-to- date; therefore, it should not be relied upon as the sole source of information. It is the responsibility of Financial Institutions (FIs), Designated Non-Financial Businesses Professions (DNFBPs) and Virtual Asset Service Providers (VASPs) to keep themselves informed and up to date with all applicable sanctions and changes thereto.

*The Lebanon (Sanctions) (Overseas Territories) Order 2020 and the Syria (United Nations Sanctions) (Cultural Property) (Overseas Territories) Order 2020