Russia / Ukraine: Cayman Islands And BVI Sanctions Update

Sanctions Orders are extended by Statutory Instrument to the British Overseas Territories, including the Cayman Islands and the British Virgin Islands (the "BVI"), to give effect to sanctions regimes implemented by the United Kingdom Government ("Sanctions Orders").

Sanctions Orders apply to any person or body incorporated or instituted in the jurisdiction, as well as any British citizen or subject ordinarily resident in the jurisdiction.  The Sanctions Orders generally restrain persons from dealing in funds or economic resources owned or controlled by, or making funds or economic resources available to, persons or entities listed under the Order ("Designated Persons").

The next raft of sanctions measures with respect to Russia's invasion of Ukraine are expected to be published by the UK, US and EU this week; some significant amendments having already been made over the past few days.  What we know so far with respect to the UK and its Overseas Territories is