From 2014 the UK has been introducing coordinated sanctions against Russia in response to its annexation of Crimea, and, from 2022, its invasion of Ukraine. These sanctions target key sources of Russian revenue, strategic industries, and individuals, groups, and companies.
This briefing describes how sanctions are applied by the UK’s fourteen Overseas Territories (OTs). Only ten of these are inhabited, and include the Cayman Islands, the British Virgin Islands, the Falkland Islands, Gibraltar, and the Turks and Caicos Islands. It also details what is known about Russian assets held in the Overseas Territories.
The Commons Library briefing, Sanctions against Russia, sets out the measures in detail. The briefing, UK OTs: an introduction, describes the Territories and their relationship with the UK.
How many Russian assets are in the OTs?
The number, distribution, and value of Russia assets to be targeted by sanctions in the OTs is unknown. Some estimates have been published:
- In February 2022, Transparency International UK linked £830 million worth of property in the UK’s OTs and Crown Dependencies (Jersey, Guernsey and the Isle of Man) to individuals close to Russian President Vladimir Putin or Russians accused of corruption.
- In November 2024 Financial Times analysis of Russian documents suggested that in 2024 US$134 million of goods were exported from the Overseas Territories to Russia.
Also in November 2024, Transparency International Russia (no longer based in Russia) published a report on continuing trade between the UK and Russia, and role of locations in the UK and the OTs in potentially facilitating this.
How are UK sanctions applied?
The long-standing policy of the UK Government is for the OTs to apply the same sanctions as the UK. Two OTs—Bermuda and Gibraltar—pass their own legislation aligned to the UK but for others, Orders in Council automatically implement the UK’s sanctions. Orders in Council are made by the UK Privy Council, and are mostly statutory instruments.
UK sanctions against Russia were extended to all the OTs (except Bermuda and Gibraltar) in The Russia (Sanctions) (Overseas Territories) Order 2020 (as amended). They have been subsequently amended and updated.
What do governments say on enforcement?
Each Territory is responsible for its own sanctions enforcement, and all the Territories have committed to work with the UK to ensure that UK sanctions are effectively applied. The UK provides technical support to all Territories through the Treasury’s Office of Financial Sanctions Implementation.
In 2024 the UK and OT Governments said that a total of £7 billion of accounts and assets (around US$9 billion) had been frozen in the OTs since 2022. This included US$220 million in Bermuda (to May 2023) and US$8.3 billion and €230 million in the Cayman Islands (around £6.5 billion) (to October 2024).
What progress has there been on publicly accessible beneficial ownership registers?
“Beneficial ownership” refers to the person who ultimately owns or controls an asset, such as property or a company. This may differ from the direct legal owner, who may not control or benefit from that asset. A register allows law enforcement agencies, for example, to check who ultimately owns an asset. The UK has had a publicly accessible register since 2016. MPs have raised concerns that a lack of similar registers in the OTs and Crown Dependencies risks national security and facilitating the undermining of sanctions.
All OTs have committed to introduce publicly accessible registers. Two have done so to 2024: Gibraltar and Monserrat. Following the passage of UK legislation in 2018, the UK Government said the OTs would introduce publicly accessible registers by December 2023. The deadline was not met.
In November 2024, the UK Government issued an update on progress. It said that St Helena, Ascension, and Tristan da Cunha and the Falklands would implement publicly accessible registers “by April 2025”. Anguilla, Bermuda, the British Virgin Islands, the Cayman Islands, and Turks and Caicos Islands said they would implement a register with “legitimate interest” access “by June 2025 or earlier”. This form of access had been accepted as an interim measure by the Conservative Government in 2023. It will allow for access by media and civil society organisations.
Territories also share information with UK law enforcement agencies under an exchange of notes agreement. In 2024 UK agencies said the arrangements “continue to add value by supporting complex investigations”.