On 19 July 2023, the UK published the Russia (Sanctions) (Overseas Territories) (No 2) Order 2023 (the Order). The Order represents a revision of the existing Russia (Sanctions) (Overseas Territories) Order 2020 and incorporates modifications from the Russia (Sanctions) (EU Exit) Regulations 2019 to apply to the UK's Overseas Territories (UKOTs) including the BVI and Cayman Islands. An equivalent regime is given effect to by local laws in Bermuda.

More specifically, the amendments introduced by the Order deal with the following:

• The prohibitions on the provision of legal advisory services and professional and business services
• The restrictions on the export of goods to non-government controlled Ukrainian territory
• The ban on the import of processed iron or steel products and revenue generating goods from Russia

The Order generally came into force on 20 July 2023, with some provisions (relating to iron and steel sanctions) deferred to 30 September 2023.

The Order harmonises the implementation of restrictions on the provision of legal advisory services within the UKOTs by tailoring regulation 54D under the Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023, which has been in force since 30 June 2023.

Russia (Sanctions) (Overseas Territories) (No 2) Order can be found here.

The Russia (Sanctions) (Overseas Territories) Order 2020 can be accessed here.

Our previous blog on the ban on legal advisory services can be found here.