Regulatory Blog

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.

On 3 December 2025, the European Commission officially added Russia to its list of high-risk jurisdictions with strategic deficiencies in anti-money laundering and counter-terrorist financing frameworks. This decision follows the adoption of Delegated Regulation (EU) 2025/1393, which aims to amend and assess the EU AML list based on a review of third countries not listed by the Financial Action Task Force but whose membership is suspended.

On 3 December 2025, the European Commission put forward a comprehensive package of legal proposals designed to address Ukraine's ongoing budgetary and defence requirements for the years 2026 and 2027. These measures are presented as a strategic investment in European security and a mechanism to facilitate a fair and sustainable peace.

Jersey has implemented the Sanctions and Asset-Freezing Amendment Order 2025 (the Amendment Order), which came into effect on 5 December 2025.

Following the invasion of Ukraine by Russia, the UK Government, alongside the member states of the European Union, the United States of America and other global stakeholders issued significant new sanctions. View a table of all the sanctions here.

European Union has issued significant and far-reaching sanctions and restrictive measures on Russia and the Russian Economy. View a table of all the sanctions here.

On 13 October 2025, the UK Office of Trade Sanctions Implementation shared a compelling case study that underscores the importance of due diligence in preventing breaches of UK trade sanctions. The case involves a multinational bank's UK branch, which successfully identified and stopped payments linked to sanctioned goods originating from Russia. This proactive action not only ensured compliance with the Russia Regulations 2019 but also safeguarded the bank's reputation and business interests.

On 15 October 2025, the UK intensified its sanctions against Russia, targeting key sectors of its economy in response to the ongoing conflict in Ukraine. These measures aim to undermine Russia's ability to fund its military operations while signalling the UK's commitment to global security and peace.

On 6 November 2025, the Cayman Islands Financial Reporting Authority published a notice requiring all entities holding frozen assets linked to Designated Persons under UK sanctions law to submit an annual report. This measure is part of global efforts to combat financial crime, terrorism financing and human rights abuses. Here is what you need to know:

On 23 October 2025, the European Union has adopted its 19th package of sanctions against Russia, marking a significant escalation in its efforts to counter Russia's ongoing aggression in Ukraine. These measures target critical sectors of the Russian economy, including energy, finance, and military industries, while also addressing circumvention tactics and third-party enablers.

On 23 October 2025, the Cyprus Bar Association issued Circular 18/2025 regarding the 19th package of sanctions imposed by the European Commission against Russia, informing its members on the sanctions targeting actions undermining Ukraine's territorial integrity, sovereignty and independence.