Financial Crime World

Sanctions Updates in the British Virgin Islands

The British Virgin Islands have seen recent changes and updates to sanctions regulations, particularly related to Russia and Belarus. This article summarizes key points from these updates.

General Licences

Several General Licences have been issued by the Governor’s Office:

  • General Licence [No. 4] 2023 (maintenance of economic resources): Authorizes the maintenance of economic resources.
  • General Licence [No. 5] 2023 (payment of reasonable professional legal fees and expenses): Allows for the payment of reasonable professional legal fees and expenses.
  • General Licence [No. 6] 2024 (payment of reasonable professional legal fees and expenses): Similar to General Licence [No. 5] 2023, but with a new effective date.

Reporting Requirement

Those who use the General Licences must report in writing to the Governor, preferably by email.

Sanctions Update

The Foreign Commonwealth and Development Office published an update of its guidance in relation to the UK Sanctions List, which introduces new specifications under the Russia sanctions regime, including a ban on ships.

Red Alert on Exporting High Risk Goods

A Red Alert was issued by Office of Financial Sanctions Implementation HM Treasury dated December 2023, regarding exporting high-risk goods.

Key Legislation

  • Russia (Sanctions) (Overseas Territories) (Amendment) Order 2024 SI 2024 No. 370: This order came into force in the Virgin Islands on March 14th, 2024.
  • General Reminder: A General Reminder was issued regarding General Licence [No. 3] 2023 (payment of reasonable professional legal fees and expenses).
  • Publication Notice: Publication notices were issued for General Licences [No. 4] 2023, [No. 5] 2023, and [No. 6] 2024.

Resources

  • Reporting forms are available for the Pre-Designation and Post-Designation Legal Fees General Licence.
  • The email address [email protected] is provided for reporting purposes.
  • Hyperlinks are provided to access the relevant documents, including the General Licences, Publication Notices, Reporting Forms, and Red Alert on Exporting High Risk Goods.

These updates are essential for individuals and businesses in the British Virgin Islands to stay compliant with sanctions regulations related to Russia and Belarus.