The Sanctions (Overseas Territories) (Amendment) Order 2019 (S.I. 2019/185)

Summary

This is a UK Order in Council that makes minor technical corrections to earlier sanctions legislation extending to the Overseas Territories, including the Cayman Islands. It removes Bermuda from certain sanctions orders (since Bermuda now applies these measures through its own domestic regulations), fixes a drafting defect in a 2018 Order, and inserts a clarifying amendment to the Libya sanctions order.

• Bermuda removed: Bermuda is omitted from the schedules of the Lebanon and Syria (UN Measures), Lebanon (UN Sanctions), and Libya (Restrictive Measures) Overseas Territories Orders, as these now apply to Bermuda via its own International Sanctions Regulations 2013.
• Libya Order clarification: Article 30(5) of the Libya (Restrictive Measures) (Overseas Territories) Order 2011 is amended to clarify that the definition of 'relevant person' applies in respect of a 'relevant institution'.
• Defective provision removed: Paragraph (3) of article 8 of the Sanctions (Overseas Territories) (Amendment of Information Provisions) Order 2018 is omitted because it was defectively drafted and could not be given effect.
• Territorial scope: The Order extends to the territories listed in Parts 1 and 2 of its Schedule, with the Cayman Islands listed in Part 1 (subject to all articles except article 2, which applies only to Part 1 territories).

The Order is purely a technical correction with no new compliance obligations for Cayman Islands entities beyond the continued application of the underlying sanctions orders as previously in force.

Deadlines

• 13th March 2019: Date the Order comes into force