The Ukraine (Sanctions) (Overseas Territories) Order 2014 - Advisory Warning No.1 of 2014 (2014-03-26)

Summary

This is a public advisory issued by the BVI Financial Services Commission notifying industry and the public that the Ukraine (Sanctions) (Overseas Territories) Order 2014 (UKSI 2014 No. 497) has been extended to the British Virgin Islands. The Order implements EU-style asset freezes against persons identified as responsible for misappropriation of Ukrainian state funds, and separately references EU Council Decisions imposing travel bans and asset freezes on persons undermining Ukraine's territorial integrity and sovereignty.

• Asset freeze: The Order freezes the assets in the British Virgin Islands (and other Overseas Territories) of persons listed in Schedule 4 of the Order who are identified as responsible for misappropriation of Ukrainian state funds.
• EU basis: The sanctions correspond to EU Council Decision 2014/119/CFSP (5 March 2014, misappropriation of state funds and human rights violations) and Decision 2014/145/CFSP (17 March 2014, travel restrictions and asset freezes for persons undermining Ukraine's sovereignty), with designated persons listed in the Annexes to those Decisions.
• Compliance direction: Persons and entities within the BVI are required to consider and apply the terms of the Order, i.e. to check whether they hold or deal with assets of listed persons and to comply with the freeze.

The advisory is informational and directs readers to the full text of the Order and the underlying EU Decisions via provided links; it does not itself set out new procedural filing requirements beyond compliance with the asset freeze.

Key obligations

• Persons and entities in the British Virgin Islands must consider and apply the terms of the Ukraine (Sanctions) (Overseas Territories) Order 2014, including freezing assets of persons listed in Schedule 4 of the Order who are identified as responsible for misappropriation of Ukrainian state funds.

Applies to

all persons and entities subject to BVI financial services regulation, financial institutions, trust and corporate services providers