The Sudan (Sanctions) (Overseas Territories) Order 2014 (2017-10-17)

Summary

This is a general industry notice issued by CIMA informing the Cayman Islands regulated community about the UK's Sudan (Sanctions) (Overseas Territories) Order 2014 (SI 2014 No. 2707). The Order extends United Nations Security Council sanctions on Sudan (and their implementation by the European Union) to specified Overseas Territories, including the Cayman Islands. It replaces and revokes three earlier sanctions orders relating to Sudan and South Sudan.

• Arms embargo: An arms embargo and a ban on providing related assistance to Sudan.
• Asset freeze and travel ban: Targets persons designated by the UN Security Council for impeding the Sudanese peace process, threatening stability in Darfur, committing violations of international humanitarian or human rights law, or breaching the arms embargo.
• Licensing exemptions: The Order allows the Governor to license certain otherwise-prohibited activities under exemptions in the sanctions regime.

The notice itself does not create new local obligations beyond directing readers to the Order's full text and explanatory note; it functions as an alert to industry (particularly those with AML/CFT and sanctions compliance responsibilities) that this UK sanctions instrument applies in the Cayman Islands and came into force on 5 November 2014.

Key obligations

• Comply with the arms embargo and prohibition on providing related assistance to Sudan
• Implement and maintain an asset freeze against persons designated by the UN Security Council under the Sudan sanctions regime
• Observe the travel ban against designated persons where applicable
• Seek a licence from the Governor before undertaking activities that would otherwise be prohibited but fall within permitted exemptions

Applies to

persons and entities subject to Cayman Islands sanctions law (including CIMA-regulated financial institutions with AML/CFT obligations)

Deadlines

• 5 November 2014: Date on which the Sudan (Sanctions) (Overseas Territories) Order 2014 comes into force