Regulatory Blog

On 24 February 2026, the Bermuda Ministry of Justice issued AML-ATF Ministerial Advisory 1/2026, emphasising the need for enhanced due diligence and enhanced ongoing monitoring on a risk-sensitive basis in business relationships involving jurisdictions identified as high-risk for money laundering and terrorist financing. This advisory aligns with the Proceeds of Crime (Anti-Money Laundering and Anti-Terrorist Financing) Regulations 2008, which mandate risk-sensitive EDD measures for transactions linked to such jurisdictions.

Effective from 18 March 2026, the Government of Jersey introduced significant amendments to the Sanctions and Asset-Freezing (Jersey) Law 2019. These changes aim to align Jersey’s sanctions framework more closely with international standards, particularly those of the UK and to strengthen Jersey’s commitment to combating financial crime and ensuring compliance with global sanctions regimes.

The European Union and the United Kingdom proceeded with the announced reduction in the price cap for Russian-origin crude oil to US$44.10 per barrel, effective 1 February 2026. This measure, part of ongoing sanctions under Regulation (EU) 833/2014, aims to curtail Russia's revenue streams while ensuring global energy market stability.

The UK Parliament has a vested interest in ensuring compliance of sanctions in the Overseas Territories since the UK is responsible, under the UN framework, for the application of sanctions in all places that the UK claims sovereignty. Added to that, the UK Sanctions and Money Laundering Act 2018 formalised the post-Brexit settlement on sanctions implementation in the OTs (with the Crown Dependencies being subject to other equivalent arrangements).

On 24 February 2026, the United Kingdom government announced its most extensive package of sanctions against the Russian Federation since 2022. Published by the Foreign, Commonwealth & Development Office, this package comprises nearly 300 new designations targeting critical Russian revenue streams, energy infrastructure and military supply chains.

On 16 February 2026, the UK Government, through the Office of Financial Sanctions Implementation, initiated a call for evidence on the implementation of the "Ownership and Control" test within UK financial sanctions regulations. This initiative requests to gather insights from businesses, legal professionals and other stakeholders to evaluate the clarity, effectiveness, and proportionality of the current framework.

On 26 January 2026, the Council of the EU announced the publication of the draft Regulation to phase out Russian pipeline gas and LNG imports. The Regulation operates as an amendment to Regulation (EU) 2017/1938 which contains measures safeguarding the security of gas supply in the EU. The ban will begin six weeks after the Regulation's entry into force, with a full ban on LNG by early 2027 and pipeline gas by autumn 2027. It is expected that the Regulation will be published in the Official Gazette imminently.

On 12 December 2025, the EU adopted Council Regulation (EU) 2025/2600, prohibiting the transfer of immobilised assets of the Central Bank of Russia, or entities acting on its behalf, back to Russia. This temporary measure is a direct response to the ongoing war of aggression against Ukraine and aims to mitigate the severe economic and security challenges posed by Russia's actions.

The recent enactment of the National Sanctions Implementation Unit Law 2025 and establishment of the National Sanctions Implementation Unit in Cyprus marks a significant milestone in the island’s sanctions enforcement regime.

On 16 October 2025, the European Securities and Markets Authority released its second consolidated report on sanctions and measures imposed in Member States for 2024. Here are the highlights:

The European Union has intensified its sanctions against Russia's "shadow fleet" in response to its ongoing aggression against Ukraine. Two recent measures highlight the EU's commitment to curbing Russia's revenue streams and addressing its violations of international law.

The Sanctions Order 2025 was published on 12 December 2025 and came into force on 11 December 2025. This updates the sanctions framework that applies across UK Overseas Territories, including the British Virgin Islands, Cayman Islands. The changes are also relevant to, by local extension, to Bermuda.