UK sanctions framework updates: key takeaways for Cayman and BVI entities

Important changes to the sanctions regimes applying to the British Overseas Territories, including the Cayman Islands and the BVI, came into force on 11 December 2025, aligning local regimes with recent updates to UK sanctions law.

The changes were introduced by the Sanctions (Miscellaneous Amendments) (Overseas Territories) Order 2025 (the Order) and key amendments include:

Expanded definition of “relevant firm”

The definition of "relevant firm" now captures (among others) art market participants, crypto asset exchange providers, custodian wallet providers, high value dealers and insolvency practitioners. This expansion will increase the number of businesses with mandatory reporting duties under applicable sanctions regimes, meaning newly defined "relevant firms" will also need to make reports where, for example:

• it knows or has reasonable cause to suspect that a person is a designated person (DP)

• it knows or has reasonable cause to suspect that it holds funds or economic resources for a prohibited person (being such persons specified under the applicable sanctions regulations)

• it failed to comply with an obligation under the applicable sanctions regulations.

Clarification of the “required payments” exception

Designated persons and persons who make a required payment on behalf of a designated person are required to inform the relevant authority that they have made such payments. This Order clarifies that a required payment will be one in which a DP (for example, a person appearing on the UK sanctions list) is required to make under or in accordance with applicable law to:

• government departments
• customs and revenue authorities
• company registrars
• financial regulators
• land authorities
• consolidated funds

For the purposes of the UK sanctions regime (as modified and extended to the Cayman Islands), references to a DP include a person who is owned or controlled directly or indirectly by the DP, enabling such persons to pay statutory fees to regulators, tax authorities and so on. By way of example, if a Cayman fund is owned or controlled by a sanctioned investor (a DP), that Cayman fund can make required statutory payments without breaching the asset freeze prohibition under the applicable sanctions regime. These updates apply to a wide range of UK / UKOT sanctions regimes, including those targeting North Korea, Libya, Russia, Iran and Venezuela.

Firms should also note that from 28 January, the UK will move to a single consolidated list for all UK sanctions designations. Any systems currently relying on the OFSI Consolidated List should transition to using the UK Sanctions List. In addition, identifiers based on the OFSI Group ID will be replaced by the Unique ID used in the UK Sanctions List for new designations, and firms may begin adopting this immediately. 

If you would like support in assessing the impact of these changes or updating your compliance framework, our regulatory team is available to assist.

Relevant firms will also be required to file annual reports on frozen assets by 30 November each year.

Read our briefing on the annual reporting obligation:

Cayman FRA sanctions reporting due 30 November

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Disclaimer

This client briefing has been prepared for clients and professional associates of Ogier. The information and expressions of opinion which it contains are not intended to be a comprehensive study or to provide legal advice and should not be treated as a substitute for specific advice concerning individual situations.

Regulatory information can be found under Legal Notice