FRA advises Cayman firms

on Russia sanctions

Cayman's Financial Reporting Authority on Tuesday (1 March) issued a public notice outlining how the recently imposed UK sanctions on Russia impact the Cayman Islands. 

Click here to read the full public notice. 

The UK government issued new restrictive economic measures in response to Russia's invasion of Ukraine. 

To date, several banks, individuals, and entities have had their assets frozen. They include but are not limited to: 

  • VTB, Russia’s second-largest bank, worth £154bn;
  • Rostec, Russia’s defence giant, responsible for $13bn of arms exports per year;
  • Kirill Shamalov, the ex-son-in-law of the Russian President Vladimir Putin and Russia’s youngest billionaire;
  • Tactical Missiles Corporation Joint Stock Company, Russian state-owned defence company and one of the most prominent manufacturers of missiles in Russia;
  • Uralvagonzavod is a wholly Russian-state owned company that produces military equipment, particularly tanks, for the Russian armed forces. It is one of the world’s largest tank manufacturers; and
  • Vladimir Putin (President of the Russian Federation), and Sergei Lavrov (Russian Foreign Minister).

What must be done?

i. check whether you maintain any accounts or hold any funds or economic resources for the persons set out in the Annex to the Notice;

ii. freeze such accounts, and other funds or economic resources and any funds which are owned or controlled by persons set out in the Annex to the Notice;

iii. refrain from dealing with the funds or assets or making them available (directly or indirectly) to such persons unless licensed by the Governor;

iv. report any findings to the FRA at, together with any additional information that would facilitate compliance with the Regulation;

v. provide any information concerning the frozen assets of designated persons to the FRA at by completing and submitting a Compliance Reporting Form (CRF) available from the website Information reported to FRA may be passed on to other regulatory authorities or law enforcement.

Failure to comply with financial sanctions legislation or to seek to circumvent its provisions is a criminal offence.

The full list of those subject to financial sanctions under the Russian Regime can be found at:

Consolidated List of Financial Sanctions – Russia Regime Asset Freeze Targets

Consolidated List of Financial Sanctions – Russia Regime Investment Ban Targets

Please see OFSI’s Guidance for the financial and investment restrictions in Russia (Sanctions) (EU Exit) Regulations 2019.

For more information please see also OFSI’s General Guidance for Financial Sanctions and the FRA’s Financial Sanctions Guidance.

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