Update On Russian Sanctions In The BVI

Sanctions continue to apply against Russian individuals and entities in the British Virgin Islands ("BVI"). A number of recent developments provide insight on how law firms and litigants are navigating the sanctions regime.

Effect of the Sanctions

By way of recap, the UK's sanctions regime has been extended to the BVI by the Russia (Sanctions) (Overseas Territories) Order 2020 (S.I. 2020/1571) (the "OT Order"), as amended. Persons in the BVI are prohibited from dealing with any funds or economic resources owned, held or controlled by a designated person or entity. Since 22 February 2022, the British Government has introduced over 1200 new designations under the Russian sanctions regime.