Cayman Islands

Global sanctions guide

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  1. Does the Cayman Islands have a sanctions regime in place? 

Yes. As a British overseas territory, the Cayman Islands implements the international sanctions obligations of the UK.

Sanctions which are in effect generally apply to:

  • any person in the Cayman Islands and any entity incorporated or constituted under the laws of the Cayman Islands
  • by virtue of the UK Orders in Council, any person elsewhere who is a British citizen, a British overseas territories citizen, a British overseas citizen, a British subject, a British National (overseas) or a British protected person and is ordinarily resident in the Cayman Islands
  1. Does the Cayman Islands implement UN sanctions? 

Though the UK is an EU member state and a member of the UN, the British overseas territories (excluding Gibraltar) are not. The Cayman Islands is nevertheless subject to the UK’s foreign policy which implements the EU’s Common Foreign and Security Policy and supports the UN’s sanctions regime. As such, UN and EU sanctions regimes have been substantially implemented and are observed in the Cayman Islands.

  1. Does the Cayman Islands implement an autonomous sanctions regime? 

Yes. As a British overseas territory, the Cayman Islands must implement all international sanctions that are extended to it through legislative action by the UK government.

As well as following the sanctions put in place by the UN and EU, the Cayman Islands has an autonomous terrorist sanctions regime and has powers over the regulated sector under the Terrorism Law (2017 Revision) and related legislation such as the Proliferation Financing (Prohibition) Law (2017 Revision) and the Proceeds of Crime Law (2017 Revision).

  1. What is the nature of the sanctions regime in the Cayman Islands? 

The most frequently applied measures are:

  • arms embargoes and bans on associated technical assistance, training and financing
  • bans on exporting equipment that might be used for internal repression
  • export controls
  • asset freezes and financial sanctions on designated individuals and corporate entities
  • travel bans on named individuals
  • bans on imports of raw materials or goods from the sanctions target

In general terms, it is a criminal offence to:

  • deal with funds or economic resources belonging to, owned, held or controlled by a designated person, if it is known, or if you have reasonable cause to suspect, that you are dealing with such funds or economic resources
  • make funds available to, or for the benefit of, a Designated person if it is known, or if you have reasonable cause to suspect, that you are making funds so available
  • make economic funds available to, or for the benefit of, a Designated person if it is known, or if you have reasonable cause to suspect, that you are making economic resources so available and, in the case of making economic resources available to a designated person, that the Designated person would be likely to exchange the economic resources, or use them in exchange, for funds, goods or services

  1. Does the Cayman Islands maintain a list of sanctioned individuals and entities? 

Yes. The Cayman Islands Monetary Authority maintains on its website a published list of sanctions orders that have been given effect to in the Cayman Islands. That list contains, under the sanctions orders relating to any particular country or group of terrorists, a direct link to the HM Treasury consolidated list of financial sanctions targets in the UK relating to that country or group.

In addition, subject to certain exceptions, the Governor of the Cayman Islands must publish in the Cayman Gazette the Governor’s designation of any person under the Terrorism Law (2017 Revision).

  1. Are there any other lists related to sanctions? 

Yes. The lists generated by HM Treasury, the Home Office and the Department for Business, Innovation & Skills in the UK are relevant.

  1. Does the Cayman Islands have a licensing or authorisation system in place? 

Yes. All sanctions-related license applications, notifications and authorizations are handled by the Governor of the Cayman Islands via the office of the Financial Secretary of the Cayman Islands.

  1. What are the consequences for a breach of sanctions in the Cayman Islands? 

It is a criminal offence to breach an obligation under a relevant sanctions measure without an appropriate license or authorization. The penalties for breaching sanctions can vary across the various regimes. However, in general terms, any individual found guilty of an offence shall be liable on conviction to a fine or imprisonment or both.

Entities acting in breach of financial sanctions can also commit a criminal offence and be liable to a fine. Where an offence has been committed by a body corporate and is proven to have been committed with the consent or connivance of, or neglect on the part of, a director, manager, secretary or similar officer of the body corporate (or anyone purporting to act in any such capacity), that individual is guilty of an offence (as well as the body corporate) and may be proceeded against accordingly. On conviction of an offence under the Terrorism Law (2017 Revision) for dealings with a terrorist organization, an entity is liable to a fine and an individual is liable to a fine or imprisonment or both.

  1. Who are the relevant regulators in the Cayman Islands and what are their contact details?

Yes. The lists generated by HM Treasury, the Home Office and the Department for Business, Innovation & Skills in the UK are relevant.

The Cayman Islands Monetary Authority has overall responsibility for the Cayman Islands’ policy on and implementation of sanctions and embargoes. It is responsible for ensuring that regulated firms have adequate systems and controls to comply with sanctions requirements.

PO Box 10052
80 Shedden Road
Elizabethan Square
Grand Cayman KY1 – 1001
Cayman Islands

T: +1 345 949 7089, +1 345 244 1639
F: +1 345 946 9730, +1 345 946 4651
E: ContactCompliance@cimoney.com.ky
W: www.cimoney.com.ky


The Financial Reporting Authority is the Cayman Islands’ Financial Intelligence Unit with responsibility for receiving, analyzing and disseminating disclosures of financial information concerning the proceeds of criminal conduct and the financing of terrorism. The Financial Reporting Authority acts under the guidance of the Anti-Money Laundering Steering Group which consists of the Attorney General, the Chief Officer, Ministry of Financial Services, Commerce and Environment, Commissioner of Police, Collector of Customs, Managing Director of the Cayman Islands Monetary Authority, the Solicitor General and the Director of Public Prosecutions.

133 Elgin Avenue, 4th Floor
New Government Administration Building
PO Box 1054
Grand Cayman KY1-1102
Cayman Islands

T: +1 345 945 6267
F: +1 345 945 6268
E: financialreportingauthority@gov.ky
W: www.fra.gov.ky

 

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