[Further update to the earlier blog posts below: On 20 November 2025, the BVI Sanctions Unit published the BVI-specific FAR form and accompanying notice. BVI returns under the new FAR reporting regime can be made by email to [email protected]. The deadline for reporting is 30 November 2025.]
[Update to the blog post below originally published on 5 November 2025: On 6 November 2025, the Cayman Islands Financial Reporting Authority published the Cayman-specific FAR form and accompanying guidance.]
There is a new sanctions reporting obligation for 2025 in the Cayman Islands and the BVI.
This first year of the annual frozen assets reporting (“FAR“) exercise requires a Cayman Islands or BVI person that hold funds or economic resources owned, held or controlled by a Designated Person (i.e. an individual or entity sanctioned by the UK Government) to file a report with that jurisdiction’s sanctions authority providing details of those frozen assets by Sunday 30 November 2025.
The relevant Cayman and BVI forms for those returns are not yet available, but are expected to be published shortly. In the meantime, they can be made in similar form to the UK template for the corresponding FAR exercise in the UK, tailored accordingly, and should be filed with the Cayman Islands Financial Reporting Authority or BVI Financial Services Commission, as appropriate.
The reporting obligation will, by way of non-exhaustive examples, apply to Cayman Islands or BVI banks holding frozen cash, or to Cayman Islands investment funds holding underlying assets that are frozen either because the Designated Person has a legal or equitable interest in those assets, or because the investment fund itself is deemed to be (in)directly owned by a Designated Person.
The report itself is relatively straightforward. It includes details of the frozen assets, including their value as at close of business on Tuesday 30 September 2025. Other assets frozen solely by other national authorities (e.g. US OFAC) do not form part of the FAR exercise.
Maples Group has significant experience in advising on Cayman Islands, BVI and EU sanctions law, including but not limited to risk assessment, upstream and downstream asset freezing measures, reporting and specific licence applications. Please reach out if you would like to check if you are in-scope of the FAR exercise, or if we can be of any other assistance.
