In response to Russia’s recent invasion of Ukraine, many jurisdictions have imposed various sanctions on a number of Russian entities and individuals, many large commercial businesses have ceased operating in Russia and some jurisdictions have banned the import of Oil produced in Russia.
Sanctions ordered by the UK government apply in the Cayman Islands by virtue of Statutory Instrument. Such sanctions apply to any person in the Cayman Islands and entity formed in the Cayman Islands. The sanctions mainly require asset freezes and the requirement to report such sanctioned individuals and entities to the Financial Reporting Authority in the Cayman Islands and include a requirement to cease doing business with such persons and entities.
We do not propose to list the specific sanctions and sanctioned individuals and entities in this brief update, but we would like to remind our clients that all Cayman entities for which we provide services should ensure that they comply with all sanctions orders and that they should also monitor and keep abreast of both existing and new sanctions which we understand will be expanded in the days and weeks to come, depending on the developing situation in the Ukraine. As before, all Cayman persons and entities should also ensure that they are aware of and in compliance with sanctions that are applicable which are imposed by other jurisdictions such as the USA and the EU.
Where IMS provides AML Officers to your entity, the Anti Money Laundering Compliance Officer will ensure that consideration is given by relevant parties to such sanctions and the identification of sanctioned entities and individuals, reporting obligations, asset freezes and any other requirements arising under the sanctions orders.
If you would like further information, please liaise with your usual IMS contact or seek legal advice from your usual firm of Cayman attorneys.
IMS is one of the longest established company management firms in the Cayman Islands. IMS is licensed by the Cayman Islands Monetary Authority to provide independent directors, company management and incorporation, mutual fund administration, captive insurance and trust services. For more information about our services, please contact us.
Disclaimer: this publication does not constitute legal or professional advice and should not be relied on as such.