Impact of UK's Sanction and Anti-Money Laundering Bill on Overseas Territories

Impact of UK's Sanction and Anti-Money Laundering Bill on Overseas Territories

May 2018

On 2 May 2018, the Sanctions and Anti-Money Laundering Bill was passed in the UK Parliament with an amendment that would require UK Overseas Territories (OTs) to introduce publicly-accessible registers of companies’ ultimate beneficial owners (UBOs).

The amendment would compel the OTs that have not established a public UBO register by the end of 2020 to do so. This relates to all the OTs: Bermuda, Anguilla, Montserrat, Turks & Caicos, Gibraltar, and also Cayman and the BVI. (Note that the Crown Dependencies, Jersey, Guernsey and the Isle of Man, are not covered by this Bill). Please click here for a link to the relevant Bill, (page 12, section 22).

The respective OT governments are not in favour of such a measure and have issued statements reiterating the strength of the existing beneficial owner identification regimes currently in operation in their jurisdictions. Please click here for a statement from Cayman Finance and here for a statement from BVI Finance.

How Vistra can support

We are monitoring this situation very closely and are in close communication with the respective governments and their representatives. It is too soon to know what the next steps will be, but we will endeavour to keep our valued clients informed on key developments and how this may impact you.

We would also reiterate that, in the meantime, it is business as usual – and, most importantly, that any potential changes are, as it stands now, at least two years away.

Should you have any further questions, in the meantime, please contact your account manager.