On 16 March 2022, the Cayman Islands Monetary Authority (CIMA) issued a notice advising financial service providers (FSPs) and virtual asset service providers (VASPs) about sanctions and restrictive measures imposed due to the Russian invasion of Ukraine.

CIMA highlighted that FSPs and VASPs should ensure that their sanctions compliance programmes remain fit-for-purpose and contain mechanisms that allows the FSP or VASP to quickly respond to the complex and swift changes to sanctions regimes.

FSPs and VASPs are reminded that should any of their underlying clients be designated on the “Consolidated List of Financial Sanctions Targets” in the United Kingdom, they must make a filing with the Cayman Islands Financial Reporting Authority and if necessary apply for a sanctions licence to be able to act in relation to the designated person.

Other sanctions lists (eg OFAC, EU, and UN) should also be considered and monitored by all FSPs, VASPs and persons conducting business in the Cayman Islands as they may be relevant but aren’t legally binding in the Cayman Islands.

Our recent blog post on the Cayman Islands position in relation to Russian sanctions can be found here and the updated UK Sanctions on Russia-Ukraine-Belarus blog post can be found here.