Attorney General, Hon. Samuel Bulgin

The Cayman Islands remains committed to the effective implementation of the Russia Sanctions Regime and maintaining its role as a global partner working towards peace and security. In response to the Russian invasion of Ukraine, many countries immediately began applying a wide range of unprecedented economic sanctions against Russia by targeting individuals and businesses with financial, trade, transport (aircraft and shipping), and immigration sanctions – all with the aim to effectively thwart their abilities to continue the warfare. 

On 16 March 2022, less than a month after the invasion, the Cayman Islands Government (CIG) established a Russia Sanctions Task Force, dubbed as “Operation Hektor”. Hektor, a name of Greek origin, means “steadfast” or “holding fast”. The Task Force was formed to coordinate, identify, and make policy amendments to implement the Russia sanctions. Twenty months later, Operation Hektor is still going strong with its efforts to implement Russia sanctions and holding monthly meetings among members.

The United Kingdom’s (UK) sanctions against Russia impact the work of multiple agencies throughout the Cayman Islands Government thus why establishing a Task Force was determined to be the best method to review sanction developments and decide what actions need to be taken by each agency, domestically and internationally. Chaired by the Director of the Financial Reporting Authority (FRA) RJ Berry, with the Cabinet Office as task force coordinator, the cross-government team known as Operation Hektor represents 11 entities that work together to ensure that the Cayman Islands has a pro-active response to the sanctions. 

The world of sanctions is dynamic and complex. Since the Russian invasion, a total of 20 amendments have been made to The Russia (Sanctions) (EU Exit) Regulations 2019 (17 amendments with one revocation in 2022 and 3 amendments to date in 2023), and 6 amendments were made to The Russia (Sanctions) (Overseas Territories) Order 2020 (4 amendments in 2022 and 2 amendments to date in 2023). 

With the ever-changing Russia sanctions regime, the Cayman Islands, as well as other British Overseas Territories (BOTs), have seen a significant increase in sanctions work, which has created a challenging environment with the existing resources. The same is true for relevant agencies in the UK. There has been enhanced engagement, including regular virtual meetings between UK Agencies, BOTs and Crown Dependencies, including ‘Deep-Dives’ on a number of relevant topics impacting the effective implementation of Russia Sanctions. In addition, the grant of any licence by the BOTs requires the consent of the UK Secretary of State. 

In May 2023, Operation Hektor members met with representatives from the Foreign, Commonwealth and Development Office (FCDO) Sanctions Directorate during their visit to the Cayman Islands. The Task Force was able to share with them the local experience of implementing sanctions work, as well as share some of the challenges that have been experienced over the past year. 

The Attorney General, Hon. Samuel Bulgin stated, “Despite the identified challenges, Operation Hektor has worked very well for the Cayman Islands. Both the Foreign, Commonwealth & Development Office and the Office of Financial Sanctions Implementation have provided positive feedback on its work, and it has been mentioned that this joint task force model is being considered by other British Overseas Territories as they see the benefit of such a framework for sanctions work.”

Her Excellency the Governor Jane Owen commented, “The UK Parliament recently marked the Fifth Anniversary of the Sanctions and Anti-Money Laundering Act (SAMLA), the first piece of post-Brexit legislation. This Act has helped shape UK foreign policy and provided a platform for the UK, along with our international partners, to implement the most severe package of sanctions ever targeted against a major economy. I am extremely grateful for all the work being undertaken across both the Cayman Islands Government and the private sector to enforce the Russia Sanctions regime and counter the illegal Russian invasion of Ukraine.”

As a result of SAMLA, over 4,000 individuals and entities have been designated; £18billion worth of Russian assets have been frozen; and 60% of Vladimir Putin’s ‘war chest’ of foreign reserves worth £275 billion have been put beyond reach. 

In June 2023, at the Deputy Governor Awards Ceremony, the work that Operation Hektor does on a daily basis to ensure that the sanctions imposed on Russia by the UK and other countries are implemented in the Cayman Islands was recognized by the Hon. Deputy Governor with the first ever World-Class Service Award.

The Premier, Hon. G. Wayne Panton commented, “I am pleased that the Operation Hektor joint task force has been a successful framework in which centralised discussions, decisions and communications can take place on arising Russia sanctions policy matters. The Cayman Islands will continue to be steadfast and proactively work towards ensuring good governance and supporting international peacekeeping.”

Operation Highlights:

The following are some key statistics on the Russia sanctions work that has been undertaken by the Cayman Islands as of September 2023:
• Four (4) General Licences (GL) have been issued by the Governor or Acting Governor, including the extension of one GL.
• Ongoing processing of licence applications – twenty-nine have been received since 1 March 2022 (22 received in 2022 and 7 in 2023).
• Two (2) Cayman flagged vessels have been deregistered by direction of the Governor. In addition, over forty (40) vessels have been deregistered as they were unable to meet the requirements of the Merchant Shipping Act due to restrictions imposed by the Russia Sanction. A number of other vessels are under review for referral for deregistration.
• Six (6) helicopters and six (6) fixed wing aircrafts have been deregistered by the Cayman Islands Civil Aviation Authority, and a number of other aircrafts are still being monitored at this time.
• Continued review and processing of Compliance Reporting Forms (CRFs) – 1,226 CRFs related to the Russia Sanctions have been received since 1 March 2022; some of these forms identify funds that have been frozen: approximately US$8.32 billion and EUR 230.1 million.
• 199 Suspicious Activity Reports (SARs) filed since 1 March 2022.