On 14 March 2024 the Russia (Sanctions) (Overseas Territories) (Amendment) Order 2024 (the “Order 2024”) came into force, introducing new reporting obligations for designated persons.
As a result, amendments to the UK Russia sanctions regime were given effect in all British Overseas Territories except Bermuda.
Similar to the changes made in December 2023 under the Russia (Sanctions) (EU Exit) Regulations 2019, which introduced reporting obligations on UK Designated Persons, the Order 2024 now requires a UK Designated Person who is a Territory person within the meaning of s21(2) and (3) of the Sanctions and Anti-Money Laundering Act 2018 (“SAMLA”) or a Territory entity as well as those who are non-territory persons, to submit a report on their funds and economic resources to the relevant authorities in the respective overseas territory.
Designated Persons must report any funds or economic resource if the value of those funds or economic resources exceeds the amount determined by the authorities of the respective overseas territory. If multiple funds or economic resources of the same type (for example, jewellery, art, bank accounts), when taken together, exceed the amount determined by the authorities of the respective overseas territory, this must also be reported.
How Gherson can help
Gherson has extensive experience in dealing with the UK and EU sanctions regimes from a number of different perspectives. Our experts have helped sanctioned clients in respect of compliance with the sanctions regulations, challenging sanctions designations and sanctions-related disputes against government authorities and/or other commercial parties.
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The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.
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