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Regulatory Round-up

UK / Cayman Islands / BVI Reimpose Sanctions on Iran

On 29 September 2025, the UK reimposed sanctions relating to Iran’s nuclear programme. This has resulted in (amongst other things) 71 individuals and entities being added back to the Consolidated List of Financial Sanctions Targets in the UK, and therefore subject to asset freezing measures under UK and (amongst others) Cayman Islands and BVI sanctions law.

This action follows the decision by the UK, France and Germany to trigger the snapback mechanism under the Joint Comprehensive Plan of Action signed between the P5+1, the EU and Iran back in 2015, which had previously lifted the majority of sanctions on Iran.

At the same time as issuing certain General Licences to industry, the UK Government has stated that it also intends to bring in further legislation to impose additional sectoral measures, targeting finance, energy, shipping, software, and other significant industries relevant to Iran’s nuclear programme. View the UK Government Statement.

Cayman Islands and BVI entities should therefore ensure they and their AML services provider are aware of the fast changing landscape of Iran-related sanctions, in line with their local AML/CFT/CPF and Sanctions obligations.

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, and specific licence applications.  Please reach out if we can be of assistance.

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