This UK Order extends the reporting requirements on financial institutions in existing Overseas Territories sanctions orders to certain other businesses and professions – namely auditors, casinos, dealers in precious metals and stones, external accountants, independent legal professionals, real estate agents, tax advisers, and trust or company service providers, and businesses and professions will commit an offence if they fail to comply with the reporting obligations.

The territories affected are Anguilla, British Antarctic Territory, British Indian Ocean Territory, Cayman Islands, the Falkland Islands, Montserrat, Pitcairn (including Henderson, Ducie and Oeno Islands), St Helena, Ascension and Tristan da Cunha, South Georgia and the South Sandwich Islands, the Sovereign Base Areas of Akrotiri and Dhekelia, the Turks and Caicos Islands and BVI.

The measures corresponds to the reporting requirements in the UK extended to the same non-financial businesses or professions in 2017.

Institutions and businesses affected are required to report if they know or suspect that one of their customers is a designated person for sanctions purposes, has dealt with funds belonging to or made funds available to a designated person, or made a false statement or provided a false document when applying for a licence to authorise activity otherwise prohibited by an asset freeze.  Failure to comply with these requirements is a criminal offence.

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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