Regulatory Blog

In June 2026, the Bermuda Government published its first-ever Proliferation Financing National Risk Assessment, prepared by the National Anti-Money Laundering Committee and aligned with updated FATF Recommendations 1 and 7. No direct PF activity, targeted financial sanctions, or assets linked to designated entities were identified in Bermuda. However, the PF NRA found there is indirect exposure to PF risks through cross-border financial activity and sectoral vulnerabilities. Bermuda’s status as an international financial centre, its expanding digital assets business sector and its diverse range of legal structures present inherent exposure to PF risks.

In brief: The Cayman Islands is preparing for its CFATF 5th Round of Mutual Evaluation, with the onsite assessment expected in late 2027. A Government Request for Proposals signals that the Cayman Islands Monetary Authority is procuring professional support for sector-level risk assessments. The evaluation will focus on the effectiveness of the jurisdiction’s AML/CFT/CPF and sanctions framework. Regulated entities should prioritise evidential readiness, including maintaining data and case studies covering up to five years.

On 30 March 2026, the Cayman Islands Department for International Tax Cooperation gazetted updated Common Reporting Standard Participating Jurisdictions and CRS Reportable Jurisdictions lists. The updates are issued pursuant to the CRS Regulations, as amended by the CRS Regulations, 2025.

On 23 June 2026, the Jersey Financial Services Commission announced updates to Appendix D1 and Appendix D2 of the AML/CFT/CPF Handbook, reflecting the latest Financial Action Task Force statements issued on 19 June 2026. These changes take effect immediately and carry practical implications for all supervised persons in Jersey.

The European Union announced a series of restrictive measures targeting individuals and entities involved in significant violations of international law, human rights, and cybersecurity. These measures were adopted on 16 March 2026, reflect the EU's commitment to safeguard global security, human rights, and the rule of law. These measures form a distinct package of measures from the 20th Package on Russia, which was released on 23 April 2026.

On 24 April 2026, the UK Office of Financial Sanctions Implementation issued a new General Licence (INT/2026/9512597) under the Sanctions and Anti-Money Laundering Act 2018, replacing the previous Legal Services General Licence which expired on 28 April 2026. The licence allows UK law firms and counsel to receive payments from designated persons under the UK Autonomous Sanctions Regimes listed in Annex 1 including, notably, Russia, without needing a separate OFSI-specific licence, provided all terms are met.

On 20 May 2026, the Russia Regulations 2026 came into force, significantly expanding the UK's sanctions regime against Russia. Made by the Secretary of State under the Sanctions and Anti-Money Laundering Act 2018, these Regulations amend the Russia Regulations 2019 and introduce a range of new trade and shipping prohibitions.

On 11 May 2026, the European Union's foreign ministers reached a unanimous agreement to impose restrictive measures on Israeli settlers and settler organisations over violence against Palestinians in the occupied West Bank. The sanctions arise against the backdrop of escalating tensions in the West Bank.

The BVI recently enacted the Mutual Legal Assistance Act 2026. This vital piece of legislation formally aligns local law with the updated Common Reporting Standard approved by the Organisation for Economic Co-operation and Development in June 2023. The 2026 Amendment was Gazetted on 5 March 2026.

The Jersey Financial Services Commission updated its sanctions list, which includes measures implemented and enforced by Jersey. These sanctions are categorised by country and specific regimes, providing an overview of the legal acts, latest news, and Jersey's enforcement regime.

On 27 April 2026, the Jersey Financial Services Commission introduced "focus examinations" as part of its 2026-2030 strategy to adopt a more risk-based and proportionate supervisory approach. These examinations are designed to assess compliance with regulatory requirements in specific, clearly defined areas, offering a streamlined alternative to full-scale examinations.

On 27 March 2026, the European Commission initiated infringement procedures against several EU Member States for failing to fully transpose key EU directives into their national laws by the required deadlines. These actions aim to ensure compliance with EU legislation and safeguard harmonisation across the EU.