On 24 March 2020, the UK government published to the official gazette the Overseas Territories Sanctions.

The Nicaragua (Sanctions) (Overseas Territories) Order 2020 No. 279

This Order gives effect in all Overseas Territories (except Bermuda and Gibraltar which implement sanctions through their own domestic legislation) to restrictive measures in view of the situation in Nicaragua, which were adopted by the Council of the European Union on 14 October 2019.

The Turkey (Sanctions) (Unauthorised Drilling Activities in the Eastern Mediterranean) (Overseas Territories) Order 2020 No 283

This Order applies to any person in the Territory, to 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 Territory to restrictive measures in view of Turkey’s unauthorised drilling activities in the Eastern Mediterranean as per Council Regulation (EU) 2019/1890 of 11th November 2019.

The Cyber (Sanctions) (Overseas Territories) Order 2020 No. 281

This Order gives effect in all Overseas Territories (except Bermuda and Gibraltar which implement sanctions through their own domestic legislation) to restrictive measures against cyber-attacks threatening the European Union or its Member States, which were adopted by the Council of the European Union on 17 May 2019.

Restrictive measures

For all the above sanction Orders, the restrictive measures include an asset freeze, which requires that all funds and economic resources belonging to, owned, held or controlled by the designated person are frozen, and prohibits funds or economic resources from being made available directly or indirectly to or for the benefit of the designated person.

There is no international or European law obligation to implement in the Territories restrictive measures adopted by the European Union. However, it is the policy of Her Majesty’s Government to give effect to these measures in the Territories in order to make sanctions as effective as possible. In accordance with usual practice, this Order provides for the relevant criminal offences and enforcement powers in the Territories.

All Sanctions orders came into force on 8 April 2020.

The Nicaragua Sanctions can be found here.

The Turkey Sanctions can be found here.

The Cyber Sanctions can be found here.