Grand Cayman, 11 July 2022 – The cross-government task force established to coordinate the application of sanctions against Russia within the Cayman Islands has spent the three months since its formation working steadily. A goal of the taskforce is to solidify the Cayman Islands’ understanding of its exposure to individuals and entities that have been designated and are subject to sanctions under the Russia Sanctions Regime. It has also worked to ensure that relevant agencies are effectively implementing the sanctions.

As part of this remit, the task force has been actively monitoring changes made by the UK Government to its Russia Sanctions Regime. 

Since February 2022, there have been ten amendments covering various measures to the UK’s Russia (Sanctions) (EU Exit) Regulations 2019. Of these, seven amendments have since been extended to the Cayman Islands; amendment one was extended automatically with amendments two to seven reflected in the Russia (Sanctions) (Overseas Territories) (Amendment) Order 2022 that came into effect on 14 April 2022.

 The UK Government has continued to update the Russia sanctions list frequently, with over 1,600 designations since the invasion of Ukraine. 

Locally, the Financial Reporting Authority (FRA) and the Cayman Islands Monetary Authority (CIMA) continue to ensure that Financial Sanctions Notices are posted and circulated in a timely manner to enable relevant firms to comply with obligations.

Since 1 March 2022, this has led to the FRA receiving 801 Compliance Reporting Forms (CRFs) related to the Russia Sanctions. Information contained in some of these forms has identified that assets valued at approximately USD8.4 billion and EUR297.8 million have been frozen since the sanctions began.

Noting that this represents over USD one billion more than initially reported in April, task force chair and Director of the FRA, R.J. Berry, commented: “Financial services providers continue to identify and report funds or economic resources owned or controlled, directly or indirectly, by designated persons, and are freezing those assets or economic resources.”

In addition, the FRA has received 144 suspicious activity reports (SARs) related to Russia Sanctions, which have been cross-referenced with the CRFs.

The General Registry which registers local and overseas companies, and the Lands and Survey Department which registers land transfers within the Cayman Islands, also continue to check their databases against the latest lists of sanctioned individuals and entities.

To ensure wide awareness of the sanctions and their implications among local industry, the Sanctions Coordinator at the FRA participated in two outreach sessions in June 2022. The first event was a presentation on the topic of the evolving sanctions landscape and provided key updates from the FRA. The virtual session was hosted by the School of International Financial Services (SIFS), attended by one hundred and forty persons. 

This was followed by a panel discussion entitled “Cayman Sanctions: The Basics and Beyond”, which was hosted by the Cayman Islands Legal Practitioners Association and the Alternative Investment Management Association.

While the taskforce is for primarily focused on fulfilling its remit within the Cayman Islands, members are also working diligently to international cooperation obligations as appropriate. 

 Emphasising the importance of the Cayman Islands being seen to be implementing the sanctions in real time, Governor Martyn Roper expressed his gratitude for all the work being undertaken across Government and the private sector to underpin and enforce the Russia Sanctions regime. 

“The Cayman Islands’ effective implementation of sanctions bolsters its strong reputation internationally as a highly responsible, efficient and professional financial services centre, as FCDO Minister for the Overseas Territories Amanda Milling confirmed on her visit earlier this year. My Office will continue to support the Cayman Islands with this vital work”, Governor Roper remarked.

Members of the Russia Sanctions task force are: the Financial Reporting Authority (Chair), Governor’s Office, Portfolio of Legal Affairs, Ministry of Financial Services and Commerce, Cabinet Office, Maritime Authority of the Cayman Islands, Cayman Islands Monetary Authority, Cayman Islands Bureau of Financial Investigations, Cayman Islands Customs and Border Control, General Registry, Civil Aviation Authority of the Cayman Islands and the Lands and Survey Department.