Cayman Islands Financial Sanctions Regime

• Did Brexit change the Cayman Islands sanction regime?


• What about US OFAC sanctions?


• What additional financial sanctions obligations apply under the Cayman Islands AML Regulations?

What are sanctions?

Sanctions are restrictions put in place by international organisations, in particular the United Nations, or countries to achieve a specific foreign policy or national security objective.

Sanctions can include trade sanctions, travel bans, transport sanctions and financial sanctions. Financial sanctions most frequently take the form of targeted asset freezes on named individuals and entities (referred to as ‘designated persons’) and can also limit the provision of financial services or restrict access to financial markets, funds and economic resources. This advisory focuses specifically on financial sanctions which may impact regulated and unregulated Cayman Islands entities.

Who must comply?

All legal and natural persons located or operating within the Cayman Islands – not simply regulated persons or persons subject to the Cayman Islands Anti-Money Laundering Regulations (as amended) (the “Cayman Islands AML Regulations”) - are subject to the Cayman Islands sanctions regime, irrespective of where their activities take place. Any person in breach of an obligation under a relevant sanctions measure will be guilty of a criminal offence.

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