1. BVI FSC Newsletter Issue No. 7 - December 2020 - Vol. 2
  2. Global Human Rights Sanctions Guidance - As required by Section 43 of the Sanctions and Anti-Money Laundering Act 2018 (‘the Sanctions Act’), the Secretary of State for Foreign and Commonwealth Affairs has provided the following guidance to assist in the implementation of and compliance with the Global Human Rights Sanctions Regulations 2020, which may be found here .
  3. The Office of Financial Sanctions Implementation provides information on the approach it takes to financial sanctions including sector and regime specific guidance, which may be found here .
  4. The Office of Financial Sanctions Implementation published the Afghanistan Guidance, which may be found here .
  5. The Office of Financial Sanctions Implementation published a penalty notice issued against Clear Junction Limited, which may be found here .
  6. The Office of Financial Sanctions Implementation published a Notice regarding the new version of the Consolidated List and list of persons, which may be found here .
  7. The Office of Financial Sanctions Implementation published a Notice regarding new regulations implemented under the Russian Sanctions Regime, which set out new restrictions on the provision of financial services for the purpose of foreign exchange reserve and asset management, which may be found here .
  8. The Live UK Sanctions Tracker has listed sanction designations under the Russia regulations since 22 February 2022, which may be found here .
  9. The Foreign Commonwealth and Development Office published a press release in relation to UK introducing new sanctions against Russia including ban on ships and fresh financial measures, which may be found here.
  10. The Foreign Commonwealth and Development Office published a travel alert, which may be found here .
  11. The Office of Financial Sanctions Implementation published updated Russia Guidance, which may be found here .

  12. The Foreign, Commonwealth & Development Office published a press release regarding UK imposing sanctions on Belarus for its role in the Russian invasion of Ukraine, which may be found here .

  13. The Foreign Commonwealth and Development Office published Russia Sanctions Guidance as of 8 March, 2022, which may be found here .

  14. The Office of Financial Sanctions Implementation has published an updated version of its enforcement and monetary penalty guidance, which may be found here .

  15. The Office of Financial Sanctions Implementation imposed a monetary penalty of £15,000 against Tracerco Limited, which may be found here .

  16. In conjunction with OFSI, the JMLIT+ Sanctions Facilitators Cell, law enforcement, private industry and regulators, the National Crime Agency (NCA) have issued a 'Red Alert' on financial sanctions evasion typologies by Russian elites and enablers, which may be found here .
  17. On 20 July 2022, to coincides with the Russia (Sanctions) (EU Exit) (Amendment) (No. 12) Regulations 2022 (the Amendment 12 Regulations) coming into force, the Office of Financial Sanctions Implementation update its Russia Guidance, which can be found here .
  18. The Office of Financial Sanctions Implementation has imposed a monetary penalty of £30,000 against UK registered company, Hong Kong International Wine and Spirits Competition Ltd (“HKIWSC”) for breaches of Ukraine (European Union Financial Sanctions)(No. 2) Regulations 2014 and Council Regulation (EU) No. 269/2014 (Ukraine Misappropriation and Human Rights), which may be found here.
  19. The Office of Financial Sanctions Implementation has updated its guidance on financial sanctions related to the Libya (Sanctions)(EU Exit) Regulations 2020, which may be found here .
  20. The Virgin Islands has issued General Licence [No. 1], 2022, which is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 as extended to the Virgin Islands with modifications by the Russia (Sanctions) (Overseas Territories) Order 2020. It may be found here .
  21. The Virgin Islands has issued General Licence [No. 1], 2023 (Oil Cap Price), which is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 as extended to the Virgin Islands with modifications by the Russia (Sanctions) (Overseas Territories) Order 2020. It may be found here .
  22. The Virgin Islands has issued General Licence [No. 2], 2023 (Wind down of Trust Services provided by Designated Persons), which is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 as extended to the Virgin Islands with modifications by the Russia (Sanctions) (Overseas Territories) Order 2020. It may be found here.
  23. The Virgin Islands has issued General Licence [No. 3], 2023 (payment of reasonable professional legal fees and expenses), which is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 (as amended) as modified by paragraph 38 of the Russia (Sanctions) (Overseas Territories) Order 2020 (as amended) and regulation 34 of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 as modified by paragraph 19 of the Republic of Belarus (Sanctions) (Overseas Territories) Order 2020. It may be found here .
  24. The Governor’s Office has issued a General Reminder regarding General Licence [No. 2] 2023 (Wind down of Trust Services provided by Designated Persons), which was granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 as extended to the Virgin Islands with modifications by the Russia (Sanctions) (Overseas Territories) Order 2020. The General Reminder may be found here .
  25. The Governor’s Office has issued General Licence [No. 4] 2023 (maintenance of economic resources), which was granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 as extended to the Virgin Islands with modifications by the Russia (Sanctions) (Overseas Territories) Order 2020. The General Licence may be found here . Additionally, the Publication Notice for General Licence [No. 4] 2023 may be found here and the reporting form with respect to Virgin Islands General Licence [No. 4] 2023, may be found here .
  26. The Governor’s Office has issued a General Reminder regarding General Licence [No. 3] 2023 (payment of reasonable professional legal fees and expenses), which was granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, as amended, as modified by paragraph 38 of the Russian (Sanctions)(Overseas Territories) Order 2020, as amended, and regulation 34 of the Republic of Belarus (Sanctions)(EU Exit) Regulations 2019 as modified by paragraph 19 of the Republic of Belarus (Sanctions)(Overseas Territories) Order 2020. The General Reminder may be found here .
  27. The Governor’s Office has issued General Licence [No. 5] 2023 (payment of reasonable professional legal fees and expenses), which was granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, as amended, (“Russia Regulations”) as modified by paragraph 38 of Schedule 2 to the Russia (Sanctions) (Overseas Territories) Order 2020, as amended, and regulation 32 of the Republic of Belarus (Sanctions)(EU Exit) Regulations 2019, as amended, (“Belarus Regulations”) as modified by paragraph 19 of Schedule 2 to the Republic of Belarus (Sanctions)(Overseas Territories) Order 2020, as amended. The General Licence may be found here . Additionally, the Publication Notice for General Licence [No. 5] 2023 may be found here .
  28. The Red Alert on Exporting High Risk Goods issued by Office of Financial Sanctions Implementation HM Treasury dated December 2023, may be found here .
  29. On 14th March 2024, the Russia (Sanctions) (Overseas Territories) (Amendment) Order 2024 SI 2024 No. 370 came into force into the Virgin Islands. Please see the attached Notice issued by the Governor’s Office, which may be found here .
  30. On 4 June 2024, the Governor’s Office issued General Licence [No. 6] 2024 (payment of reasonable professional legal fees and expenses), which was granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, as amended, (“Russia Regulations”) as modified by paragraph 38 of Schedule 2 to the Russia (Sanctions) (Overseas Territories) Order 2020, as amended, and regulation 32 of the Republic of Belarus (Sanctions)(EU Exit) Regulations 2019, as amended, (“Belarus Regulations”) as modified by paragraph 19 of Schedule 2 to the Republic of Belarus (Sanctions)(Overseas Territories) Order 2020, as amended. The General Licence may be found here .  Additionally, the Publication Notice for General Licence [No. 6] 2024 may be found here .

    Reporting Requirement

    Those who use the General Licence must report in writing to the Governor, preferably by email, to [email protected].  See hyperlinks for reporting forms for the Pre-Designation and Post-Designation Legal Fees General Licence.
  31. The Foreign Commonwealth and Development Office published an update of its guidance in relation to the UK Sanctions List and the revocation and re-specification of 17 ships under the Russia sanctions regime. These sanctions target vessels which attempt to undermine sanctions in support of the Russian oil and military goods trades and may be found here .
  32. On 12 September 2024, the Office of Financial Sanctions Implementation (OFSI) released an advisory on North Korean IT workers. The advisory identifies key threats posed by North Korean IT workers who seek to breach UK financial sanctions on the Democratic People's Republic of Korea (DPRK aka North Korea), and provides recommendations on how firms can mitigate their risk exposure. The advisory is aimed at the Information Technology (IT), Cryptocurrency, Electronic Money Institutions (EMI), Money Service Businesses (MSB), and Professional Services sectors and may be found here .
  33. On 17 September 2024, the United Nations Security Council Committee has amended one entry on its sanctions list of individuals and entities. The link to the entry on the United Nations Security Council Sanctions List may be found here .
  34. The Office of Financial Sanctions Implementation published a penalty notice issued against Integral Concierge Services (ICSL), which may be found here .
  35. On 15 October 2024, the Governor issued the Virgin Islands General Licence [No. 7], 2024 (maintenance of economic resources) which is granted under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 as extended to the Virgin Islands with modifications by the Russia (Sanctions) (Overseas Territories) Order 2020. It may be found here.

    The details for what the General Licence permits a Registered Agent or a Corporate Services Provider to do may be found here.

    Reporting Reqirement

    Those who use the General Licence must report in writing to the Governor, preferably by email, to [email protected], using the form found here.

    Alternatively, completed forms can be posted to:
    Governor’s Office
    Waterfront Drive
    Road Town, Tortola
    British Virgin Islands

    Reporting is due within fourteen days of a payment permitted under the General Licence.

    Those using the General Licence must keep records of its use for a period of six (6) years. Any Registered Agent or Corporate Services Provider with an outstanding licence application with the Governor’s Office who intends to use this General Licence should immediately contact the Governor’s Office.
  36. On 8 November 2024, the United Nations Security Council Committee established pursuant to resolution 1591 (2005) added two entries to its sanctions list of individuals and entities. The link to the entry on the United Nations Security Council Sanctions List may be found here.
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