The Sanctions (Miscellaneous Amendments) (Overseas Territories) Order 2025

At the Court at Buckingham Palace, the 10th day of December 2025

Present,

The King’s Most Excellent Majesty in Council

His Majesty, in exercise of the powers conferred on Him by section 63(3)(c) and (4) of the Sanctions and Anti-Money Laundering Act 20181, is pleased, by and with the advice of His Privy Council, to make the following Order:

1. Citation, commencement and extent

(1) This Order may be cited as the Sanctions (Miscellaneous Amendments) (Overseas Territories) Order 2025 and comes into force on 11th December 2025.

(2) This Order extends to each British overseas territory listed in Schedule 1.

2. Amendments to Overseas Territories Orders

(1) Schedule 2 to the Venezuela (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Venezuela (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 2.

(2) Schedule 2 to the Democratic People’s Republic of Korea (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Democratic People’s Republic of Korea (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 3.

(3) Schedule 2 to the Democratic Republic of the Congo (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Democratic Republic of the Congo (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 4.

(4) Schedule 2 to the South Sudan (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the South Sudan (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 5.

(5) Schedule 2 to the Iran (Sanctions) (Nuclear) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 6.

(6) Schedule 2 to the ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 7.

(7) Schedule 2 to the Republic of Guinea-Bissau (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Republic of Guinea-Bissau (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 8.

(8) Schedule 2 to the Counter-Terrorism (International Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 9.

(9) Schedule 2 to the Counter-Terrorism (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 10.

(10) Schedule 2 to the Republic of Belarus (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 11.

(11) Schedule 2 to the Zimbabwe (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Zimbabwe (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 12.

(12) Schedule 2 to the Chemical Weapons (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Chemical Weapons (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 13.

(13) Schedule 2 to the Syria (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Syria (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 14.

(14) Schedule 2 to the Russia (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Russia (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 15.

(15) Schedule 2 to the Guinea (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Guinea (Sanctions) (EU Exit) Regulations 2019 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 16.

(16) Schedule 2 to the Cyber (Sanctions) (Overseas Territories) (No. 2) Order 2020 (modifications to be made in the extension of the Cyber (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 17.

(17) Schedule 2 to the Bosnia and Herzegovina (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Bosnia and Herzegovina (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 18.

(18) Schedule 2 to the Nicaragua (Sanctions) (Overseas Territories) (No. 2) Order 2020 (modifications to be made in the extension of the Nicaragua (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 19.

(19) Schedule 2 to the Central African Republic (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Central African Republic (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 20.

(20) Schedule 2 to the Lebanon (Sanctions) (Assassination of Rafiq Hariri and others) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Lebanon (Sanctions) (Assassination of Rafiq Hariri and others) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 21.

(21) Schedule 2 to the Somalia (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Somalia (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 22.

(22) Schedule 2 to the Global Human Rights Sanctions (Overseas Territories) Order 2020 (modifications to be made in the extension of the Global Human Rights Sanctions Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 23.

(23) Schedule 2 to the Mali (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Mali (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 24.

(24) Schedule 2 to the Iraq (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Iraq (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 25.

(25) Schedule 2 to the Sudan (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Sudan (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 26.

(26) Schedule 2 to the Afghanistan (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Afghanistan (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 27.

(27) Schedule 2 to the Yemen (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Yemen (Sanctions) (EU Exit) (No. 2) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 28.

(28) Schedule 2 to the Unauthorised Drilling Activities in the Eastern Mediterranean (Sanctions) (Overseas Territories) Order 2020 (modifications to be made in the extension of the Unauthorised Drilling Activities in the Eastern Mediterranean (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 29.

(29) Schedule 2 to the Libya (Sanctions) (Overseas Territories) Order 2021 (modifications to be made in the extension of the Libya (Sanctions) (EU Exit) Regulations 2020 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 30.

(30) Schedule 2 to the Global Anti-Corruption Sanctions (Overseas Territories) Order 2021 (modifications to be made in the extension of the Global Anti-Corruption Sanctions Regulations 2021 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 31.

(31) Schedule 2 to the Myanmar (Sanctions) (Overseas Territories) Order 2021 (modifications to be made in the extension of the Myanmar (Sanctions) Regulations 2021 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 32.

(32) Schedule 2 to the Haiti (Sanctions) (Overseas Territories) Order 2022 (modifications to be made in the extension of the Haiti (Sanctions) Regulations 2022 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 33.

(33) Schedule 2 to the Iran (Sanctions) (Overseas Territories) Order 2023 (modifications to be made in the extension of the Iran (Sanctions) Regulations 2023 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 34.

(34) Schedule 2 to the Global Irregular Migration and Trafficking in Persons Sanctions (Overseas Territories) Order 2025 (modifications to be made in the extension of the Global Irregular Migration and Trafficking in Persons Sanctions Regulations 2025 to each British overseas territory listed in Schedule 1) is amended in accordance with Schedule 35.

Schedules

Schedule 1

British overseas territories

Article 1(2)

• Anguilla
• British Antarctic Territory
• British Indian Ocean Territory
• Cayman Islands
• Falkland Islands
• Montserrat
• Pitcairn, Henderson, Ducie and Oeno Islands
• St Helena, Ascension and Tristan da Cunha
• South Georgia and the South Sandwich Islands
• The Sovereign Base Areas of Akrotiri and Dhekelia in the Island of Cyprus
• Turks and Caicos Islands
• Virgin Islands

Schedule 2

Amendments to Schedule 2 to the Venezuela (Sanctions) (Overseas Territories) Order 2020

Article 2(1)

1. In paragraph 2(b)(i), in the definition of “authorised officer”, after paragraph (c)(iv) insert—

“(iva) regulation 49A (finance: disclosure to the Governor),”.

2. After paragraph 6, insert—

“6A. Omit regulation 5A (conditions for the designation of persons by name) (including the heading)”.

3. After paragraph 17 insert—

“17A. For regulation 33ZA (finance: exception from prohibitions for required payments) substitute—

“Finance: exception from prohibitions for required payments 33ZA.

(1) This regulation applies to required payments within the meaning of paragraph (2).

(2) A required payment is a payment which a designated person is required to make under or by virtue of any enactment which applies in the Territory to—

(a) a government department or body, (b) a customs authority, (c) a revenue authority, (d) a registrar of companies, (e) a financial regulator, (f) a land authority, or (g) a consolidated fund.

(3) The prohibitions in regulations 11 (asset freeze in relation to designated persons) and 13 (making funds available for benefit of designated persons) are not contravened by a person making a required payment.

(4) Where a required payment is made by a person other than a designated person, the prohibition in regulation 11 is not contravened by the designated person making a reimbursement payment to that person.

(5) The reference in paragraph (3) to a person making a required payment includes a designated person, but only where they are making a required payment on their own behalf.

(6) For the purposes of this regulation, references to a designated person are to be read as including a person who is owned or controlled directly or indirectly (within the meaning of regulation 7) by the designated person.

(7) In this regulation—

“designated person” has the same meaning as it has in Part 3 (finance);

“reimbursement payment” means a repayment from the designated person to the person who made a required payment which is of the same amount as that required payment.”.

4. After paragraph 25 insert—

“25A. In regulation 41A (finance: reporting obligations for required payments)—

(a) in paragraphs (1), (2) and (3), for “Treasury” substitute “Governor”; (b) in paragraph (5), for “33ZA(8)”, in both places it occurs, substitute “33ZA(7)”.”.

5. In paragraph 26, in the substituted regulation 42 (“relevant firm”)—

(a) in paragraph (1), after sub-paragraph (f), insert—

“(g) a cryptoasset exchange provider; (h) a custodian wallet provider; (i) a high value dealer; (j) an art market participant; (k) an insolvency practitioner; (l) a firm or sole practitioner (a “letting agent”) that carries out, or whose employees carry out, letting agency work.”;

(b) after paragraph (2) insert—

“(2A) In paragraph (1), a “cryptoasset exchange provider” means a firm or sole practitioner that by way of business provides one or more of the following services, including where the firm or sole practitioner does so as creator or issuer of any of the cryptoassets involved—

(a) exchanging, or arranging or making arrangements with a view to the exchange of, cryptoassets for money or money for cryptoassets, (b) exchanging, or arranging or making arrangements with a view to the exchange of, one cryptoasset for another, or (c) operating a machine which utilises automated processes to exchange cryptoassets for money or money for cryptoassets.

(2B) In paragraph (1), a “custodian wallet provider” means a firm or sole practitioner that by way of business provides services to safeguard, or to safeguard and administer—

(a) cryptoassets on behalf of its customers, or (b) private cryptographic keys on behalf of its customers in order to hold, store and transfer cryptoassets.

(2C) For the purposes of this regulation—

(a) “cryptoasset” means a cryptographically secured digital representation of value or contractual rights that uses a form of distributed ledger technology and can be transferred, stored or traded electronically;

(b) “money” means—

(i) money in sterling, (ii) money in any other currency, or (iii) money in any other medium of exchange,

but does not include a cryptoasset;

(c) in sub-paragraphs (a) to (c) of paragraph (2A), “cryptoasset” includes a right to, or interest in, the cryptoasset.

(2D) In paragraph (1), a “high value dealer” means a firm or sole trader that by way of business trades in goods (including an auctioneer dealing in goods), when the firm or sole trader makes or receives, in respect of any transaction, a payment or payments in cash of at least 10,000 euros in total, whether the transaction is executed in a single operation or in several operations which appear to be linked.

(2E) In paragraph (1), an “art market participant” means, subject to paragraph (2F), a firm or sole practitioner that by way of business trades in, or acts as an intermediary in the sale or purchase of, works of art and the value of the transaction, or a series of linked transactions, amounts to 10,000 euros or more.

(2F) A firm or sole practitioner is not an art market participant for the purposes of paragraph (2E) in relation to the sale or storage of a work of art which is created by, or is attributable to, a member of the firm or the sole practitioner.

(2G) For the purposes of this regulation, “work of art” means—

(a) any mounted or unmounted painting, drawing, collage, decorative plaque or similar picture that was executed by hand, but does not include any technical drawing, map or plan; (b) any original engraving, lithograph or other print which—

(i) was produced from one or more plates executed by hand by an individual who executed them without using any mechanical or photomechanical process, and (ii) either is the only one produced from the plate or plates or is comprised in a limited edition; (c) any original sculpture or statuary, in any material; (d) any sculpture cast which—

(i) was produced by or under the supervision of the individual who made the mould or became entitled to it by succession on the death of that individual, and (ii) either is the only cast produced from the mould or is comprised in a limited edition; (e) any tapestry or other hanging which—

(i) was made by hand from an original design, and (ii) either is the only one made from the design or is comprised in a limited edition; (f) any ceramic executed by an individual and signed by that individual; (g) any enamel on copper which—

(i) was executed by hand, (ii) is signed either by the person who executed it or by someone on behalf of the studio where it was executed, (iii) either is the only one made from the design in question or is comprised in a limited edition, and (iv) is not comprised in an article of jewellery or an article of a kind produced by goldsmiths or silversmiths; (h) any mounted or unmounted photograph which—

(i) was printed by or under the supervision of the photographer, (ii) is signed by the photographer, and (iii) either is the only print made from the exposure in question or is comprised in a limited edition.

(2H) In paragraph (1), an “insolvency practitioner” means a person that administers insolvency proceedings, including by receiving or managing the money or other property of any person subject to any form of insolvency proceedings, in accordance with any law relating to insolvency which applies for the time being in the Territory.

(2I) In paragraph (1), “letting agency work” means work—

(a) consisting of things done in response to instructions received from—

(i) a person (a “prospective landlord”) seeking to find another person to whom to let land for a term of a month or more, or (ii) a person (a “prospective tenant”) seeking to find land to rent for a term of a month or more, and

(b) done—

(i) in relation to a prospective landlord, from the point that the prospective landlord instructs a letting agent, or (ii) otherwise in the course of concluding an agreement for the letting of land for a term of a month or more.

(2J) For the purposes of paragraph (2I)—

“land” includes part of a building and part of any other structure;

“letting agency work” does not include the things listed in paragraph (2K) when done by, or by employees of, a firm or sole practitioner if neither the firm nor sole practitioner, nor any of their employees, does anything else within paragraph (2I).

(2K) Those things are—

(a) publishing advertisements or disseminating information; (b) providing a means by which a prospective landlord or a prospective tenant can, in response to an advertisement or dissemination of information, make direct contact with a prospective tenant or a prospective landlord; (c) providing a means by which a prospective landlord and a prospective tenant can communicate directly with each other; (d) the provision of legal or notarial services by a barrister, advocate, solicitor or other legal representative communications with whom may be the subject of a claim to professional privilege.”.

(c) in paragraph (3)—

(i) omit the “and” at the end of sub-paragraph (a); (ii) after sub-paragraph (a) insert—

“(aa) in the case of a relevant firm within paragraph (1)(j)—

(i) in the course of trading, or acting as an intermediary in the sale or purchase of, works of art when the value of the transaction, or a series of linked transactions, amounts to 10,000 euros or more, or (ii) in the course of storing works of art where the value of the works of art so stored for a person amounts to 10,000 euros or more, and”.

6. After paragraph 34 insert—

“34A. For regulation 49A (finance: disclosure to the Treasury) substitute—

“Finance: disclosure to the Governor 49A.

(1) A relevant public authority may disclose information to the Governor or an authorised officer if the disclosure is made for the purpose of enabling or assisting the Governor or the authorised officer to discharge any of their functions in connection with any sanctions regulations contained in these Regulations.

(2) In this regulation, “relevant public authority” means—

(a) any person holding or acting in any office under or in the service of—

(i) the Crown in right of the Government of the United Kingdom; (ii) the Crown in right of the Government of the Territory, or

(b) any other person exercising functions of a public nature.”.

7. In paragraph 60—

(a) in sub-paragraph (c), for “paragraph 1” substitute “paragraph 1(1)”; (b) for sub-paragraph (d), substitute—

“(d) in paragraph 6 (judicial decisions etc.), for “United Kingdom” substitute “Territory”;”; (c) after sub-paragraph (d), insert—

“(e) for paragraph 10 (insolvency) substitute—

“Insolvency 10.

(1) To enable anything to be done in connection with—

(a) any insolvency and restructuring proceedings relating to an insolvent person, or (b) proceedings, under the insolvency law of any country other than the Territory, that correspond to the proceedings in paragraph (a),

provided that any payments made directly or indirectly to a designated person are credited to a frozen account.

(2) In this paragraph—

“insolvency and restructuring proceedings” includes—

(a) any proceedings, under any law relating to insolvency for the time being in force in the Territory, whereby, for a set period of time, the creditors of an insolvent person are precluded from taking action against the insolvent person; (b) any arrangement, under any such law, involving an agreement between an insolvent person and its creditors which is administered by an insolvency practitioner, and “insolvency practitioner” has the meaning given by regulation 42(2H); (c) any administration procedure, under any such law, in accordance with which proceedings, actions or other steps against an insolvent person are prohibited for the purpose of allowing the insolvent person to do either or both of the following—

(i) reorganise assets; (ii) realise assets; (d) any receivership procedure, under any such law, whereby a secured creditor of an insolvent person can appoint an administrative receiver to manage and sell the insolvent person’s business and assets; (e) any proceedings, under any such law, for the winding up of a company but excluding any proceedings relating to the winding up of a solvent company; (f) any arrangement or scheme sanctioned by a court, under any such law, between a company and its members or creditors which can be used to effect solvent reorganisation of the company or effect insolvent restructurings;

“insolvent person” means a person (“P”), other than an individual, where—

(a) P is unable to pay its debts as they fall due, or (b) the value of P’s assets is less than the amount of its liabilities, taking into account its contingent and prospective liabilities.”.