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The Overseas Territories and Russia sanctions

From 2014 the UK has been introducing coordinated sanctions against Russia in response to its annexation of Crimea, and, from 2022, its invasion of Ukraine. These sanctions target key sources of Russian revenue, strategic industries, and individuals, groups, and companies.

This briefing describes how sanctions are applied by the UK’s 14 Overseas Territories (OTs). 

The Commons Library briefing, Sanctions against Russia, sets out the sanctions measures in detail. The briefing, UK OTs: an introduction, describes the Territories and their relationship with the UK.

How many Russian assets are in the OTs?

The number, distribution, and value of Russia assets to be targeted by sanctions in the OTs is unknown. Some estimates have been published:

• In February 2022, Transparency International UK linked £830 million worth of property in the UK’s OTs and Crown Dependencies (Jersey, Guernsey and the Isle of Man) to individuals close to Russian President Vladimir Putin or Russians accused of corruption.
• In November 2024 Financial Times analysis of Russian documents suggested that in 2024 US$134 million of goods were exported from the Overseas Territories to Russia.

Also in November 2024, Transparency International Russia (no longer based in Russia) published a report on continuing trade between the UK and Russia, and role of locations in the UK and the OTs in potentially facilitating this.

How are UK sanctions applied?

The long-standing policy of the UK Government is for the OTs to apply the same sanctions as the UK. Two OTs—Bermuda and Gibraltar—pass their own legislation aligned to the UK but for others, Orders in Council automatically implement the UK’s sanctions. Orders in Council are made by the UK Privy Council, and are mostly statutory instruments.

UK sanctions against Russia were extended to all the OTs (except Bermuda and Gibraltar) in The Russia (Sanctions) (Overseas Territories) Order 2020 (as amended). They have been subsequently amended and updated.

What do governments say on enforcement?

Each Territory is responsible for its own sanctions enforcement, and all the Territories have committed to work with the UK to ensure that UK sanctions are effectively applied. The UK provides technical support to all Territories through the Treasury’s Office of Financial Sanctions Implementation.

In 2024 the UK and OT Governments said that a total of £7 billion of accounts and assets (around US$9 billion) had been frozen in the OTs since 2022. This included US$220 million in Bermuda (to May 2023) and US$8.3 billion and €230 million in the Cayman Islands (around £6.5 billion) (to October 2024).

Update log

March 2026: Removed section on registers and published as a separate briefing on beneficial ownership registers.