Ensuring Sanctions Compliance in the Virgin Islands
In the British Overseas Territory of Virgin Islands, compliance with UK Orders in Council extending EU, UN, and UK sanctions is mandatory. The Governor's Office plays a key role in enforcing sanctions, including publishing lists of designated persons and restricted goods. The Governor can cooperate in international investigations and grant licenses for specified activities. Compliance obligations apply to residents, British citizens, and registered entities in the Territory.
- Sanctions Compliance
- Virgin Islands
- Governors Office
- International Sanctions
- British Overseas Territory
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Sanctions Sanctions The Role of the Industry and the Governor s Office in Ensuring Compliance Presented by: Maria Mays, Head of Policy Office of the Governor
Sanctions Orders Sanctions Orders As a British Overseas Territory, the Virgin Islands is subject to UK Orders in Council which are passed by The Privy Council, extending the provisions in EU, UN and UK sanctions to the Overseas Territories. It is compulsory for the Virgin Islands to implement and administer Sanctions Orders to comply with its international obligations.
Who must Comply? Who must Comply? The requirement to ensure compliance with sanctions obligations apply to any person: any person in the Territory, 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, or a body incorporated or constituted under the law of any part of the Territory, and any person onboard a ship or aircraft that is registered in the Territory.
The Role of the Governors Office The Role of the Governor s Office The Governor of the Virgin Islands is the Competent Authority with responsibility for enforcing Orders-in-Council relative to international sanctions. To publish a list of designated persons and a list of restricted goods and keep the lists up to date. This requirement can be satisfied by publication in the gazette.
The Role of the Governors Office The Role of the Governor s Office To co-operate with an international investigation relating to funds of designated persons etc. The Governor is also empowered to grant licenses in justified cases, which permit the conduct of specified activities otherwise not permitted under the relevant Orders-in-Council The Governor s responsibilities can be delegated
Licences Granted by the Governor Licences Granted by the Governor To conduct certain transactions with consent from the United Kingdom Secretary of State Legal fees Some prior contracts Extraordinary expenses Routine maintenance of funds/assets
Licences Granted by the Governor Licences Granted by the Governor Amend a licence granted Refuse an application for a license Revoke licence
Application Application Is a licence required? Which sanctions order Is a licence justified
Application Application Application Form The Process Internal Next steps Approvals
Ongoing Monitoring and Reporting Ongoing Monitoring and Reporting Conditions Reporting
Ongoing Monitoring Ongoing Monitoring Ongoing monitoring and testing should be conducted on a regular and frequent basis: conduct regular checks of the Consolidated Sanctions Lists to note any new updates on the EU,UN & UK sanctions and embargo regimes. Licensees are expected to: understand their obligations; and assess the effectiveness of their procedures.
Sanctions Screening Sanctions Screening UK: sanctions-consolidated-list-of-targets www.gov.uk/government/publications/financial- www.legislation.gov.uk FIA website: FSC website: www.fiabvi.org www.bvifsc.vg/library/sanctions
Sanctions Breaches Sanctions Breaches Where there is reasonable cause to suspect an applicant for business or customer is designated and has not been granted a license by the Governor: Immediately freeze all funds or economic resources; Do not enter into any financial transactions or provide financial assistance or economic services; Undertake ECDD measures; File a SAR/STR with the FIA/FSC. Report the suspicion to the Governor.
Sanctions Breaches: Process and Procedures Sanctions Breaches: Process and Procedures Always report a suspected breach to the Governor s Office and FIA Role of the Governor s Office Role of FIA
Thank You! Thank You! www.gov.uk/world/organisations/the-governors-office-british- virgin-islands www.facebook.com/ukinbvi/ https://twitter.com/bvigovoff
