General Licence Under Russian Sanctions Issued (2022-10-05)

Summary

This CIMA notice announces that on 4 October 2022 the Governor of the Cayman Islands issued General Licence GL/2022/0001 under the Russia sanctions regime (made under the Russia (Sanctions) (EU Exit) Regulations 2019, as extended to the Cayman Islands by the Russia (Sanctions) (Overseas Territories) Order 2020).

• Frozen investment interests: A Relevant Investment Fund or Fund Manager may redeem, withdraw or otherwise deal with a frozen investment interest, subject to the conditions set out in the licence itself.
• Payments from frozen accounts: Payments may be made for basic needs, routine holding and maintenance, and legal fees from frozen accounts, subject to the conditions set out in the licence itself.

The notice is aimed at CIMA-regulated investment funds and fund managers that may hold or manage frozen Russian-linked assets and wish to rely on this general licence. It does not itself set out the full terms of the licence -- entities intending to use it are directed to consult the licence document for the specific permissions and usage requirements before acting.

Importantly, the notice imposes a reporting obligation: any Relevant Investment Fund or Fund Manager regulated by CIMA that uses the licence must notify CIMA of that use within three business days, by emailing a specified address. This is a time-sensitive compliance step tied to any reliance on the licence, separate from the substantive sanctions permissions themselves.

Key obligations

• A Relevant Investment Fund or Fund Manager regulated by CIMA that uses General Licence GL/2022/0001 must notify CIMA of such use within three business days, sent to generallicencenotification@cima.ky.
• Persons intending to use the licence must consult the full text of the licence for the relevant permissions and usage requirements before relying on it.

Applies to

Relevant Investment Fund, Fund Manager

Deadlines

• within three business days: CIMA-regulated Relevant Investment Fund or Fund Manager must notify CIMA of its use of General Licence GL/2022/0001 within three business days of such use.