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Gibraltar Compliance with International Sanctions: A Model of Effectiveness

The Rock’s unwavering commitment to upholding international sanctions has earned it a reputation as a reliable and responsible member of the global community.

Background

For years, Gibraltar has implemented sanctions with precision and finesse, working in tandem with the United Nations, the European Union, and the United Kingdom to achieve specific policy and security objectives. A key milestone in this journey was the passage of the Sanctions Act 2019, which provides for the automatic recognition and enforcement of UN, UK, and EU sanctions.

Streamlined Process

This legislation has streamlined the process, ensuring that Gibraltar’s compliance is swift and efficient. The Sanctions Act 2019 and the Terrorist-Asset Freezing Regulations 2011 enable the relevant competent authorities in Gibraltar to designate separate sanctions if deemed necessary.

Designations and Licensing

Although there are currently no such designations in place, these measures demonstrate the government’s willingness to take decisive action when circumstances demand it. The UK’s Office of Financial Sanctions Implementation (OFSI) has also been instrumental in Gibraltar’s compliance efforts, providing real-time updates on financial sanctions targets and designations.

Exceptions and Licensing

While sanctions can sometimes present challenges, Gibraltar has developed a robust framework for managing exceptions and licensing. Specifically, the Sanctions Act 2019 outlines specific exemptions and licensing powers that allow otherwise prohibited transactions to take place in certain circumstances.

The Competent Authority

The Competent Authority is responsible for issuing licences, which require written authorisation permitting an otherwise prohibited act. These licences can be requested from the Competent Authority and are essential for facilitating legitimate trade and economic activity while maintaining compliance with international sanctions.

Financial Intelligence Unit (GFIU)

Gibraltar’s financial intelligence unit (GFIU) plays a critical role in monitoring and reporting on frozen funds and economic resources. The GFIU has developed an online reporting system (THEMIS), which enables users to submit reports of frozen assets, designated persons, and credits to frozen accounts.

Reporting Process

The agency also provides guidance on the reporting process for suspected breaches. For more information on export controls related to sanctions, individuals can contact HM Customs (Gibraltar) at exportcontrol.sanctions@gibraltar.gov.gi. Immigration sanctions-related queries should be directed to the Borders and Coastguard Agency at immigration@bca.gov.gi.

Additional Resources

Additional resources are available through the UK’s Office of Financial Sanctions Implementation (OFSI), including guidance notes, maritime guidelines, and country-specific information on Russia. The Trusts General Licence and Sanctions Licences also provide valuable insights into Gibraltar’s compliance efforts.

Conclusion

Ultimately, Gibraltar’s commitment to international sanctions is a testament to its dedication to upholding global norms and maintaining the highest standards of financial integrity. As a responsible and compliant jurisdiction, the Rock continues to serve as a model for other countries seeking to navigate the complexities of sanctions implementation.