Financial Crime World

Montserrat’s Financial Sanctions: A Guide to Compliance

Montserrat’s financial sanctions are an essential part of our country’s sanctions regime, aimed at targeting the funds and assets of designated or listed persons. As a key stakeholder in Montserrat’s regulated financial sectors, it is crucial that you understand your obligations under these sanctions.

Obligations Under Financial Sanctions

To comply with international measures, you are required to:

  • Check whether you maintain accounts or hold funds for designated or listed persons.
  • Freeze such accounts and refrain from dealing with or making available these funds unless licensed by the Minister.
  • Notify the Governor of any such actions.

Ongoing Screening

As sanctions measures are subject to change, it is essential that you conduct ongoing screening to ensure compliance. This includes:

  • Checking the Consolidated List for updates
  • Verifying whether targets included in the list are also subject to prohibitions under Montserrat’s Sanctions Regime

The Consolidated List: A Key Resource

The Consolidated List is a vital tool for identifying targeted individuals and entities. This list, maintained by HM Treasury (UK), includes all financial sanctions targets under United Nations Security Council Resolutions and UK legislation. The list is divided by country and provides individual lists for each regime.

Additional Guidance and Resources

For further guidance on sanctions compliance, we recommend:

  • Consulting the Treasury’s guidance provided in relation to Consolidated Lists
  • Referencing the Office of Foreign Assets Control (OFAC) guidance, particularly if your business has ties to the United States

Important Note: US Sanctions

While Montserrat does not provide guidance on foreign sanctions, it is essential that you are aware of OFAC sanctions and their extra-territorial effect. Failure to comply with these sanctions could result in criminal or civil liability in the United States.

Conclusion

In conclusion, it is crucial that financial institutions and businesses operating in Montserrat’s regulated sectors understand their obligations under our country’s sanctions regime. By following this guide and consulting relevant resources, you can ensure compliance and avoid any potential risks associated with non-compliance.