Cayman Islands Sanctions Update Post-Brexit

All Cayman Islands persons or entities are subject to applicable Cayman Islands sanctions legislation.  In addition, persons or entities that carry on 'relevant financial business' in or from the Cayman Islands are subject to the Anti-Money Laundering Regulations (2020 Revision) and are required to implement policies and procedures that include checking customers, applicants for business, beneficial owners, transactions, service providers and other relevant parties against sanctions lists applicable in the Cayman Islands. 

Sanctions legislation in the Cayman Islands (a "Sanctions Order") is extended to the Cayman Islands, as a British Overseas Territory, by United Kingdom ("UK") Statutory Instrument and therefore largely mirrors the UK Sanctions Regulations.  Other Cayman Islands legislation also empowers certain Cayman Islands authorities to impose sanctions.