The Iran (Sanctions) (Overseas Territories) Order 2023

The Iran (Sanctions) (Overseas Territories) Order 2023 was published on legislation.gov.uk, the official platform of the UK government to publicize legal documents. It extends – with some minor modifications – the application of the new Iran (Sanctions) Regulations 2023 (SI 2023/1314) to nearly all British Overseas Territories except Bermuda and Gibraltar (which implement „sanctions under their own legislative arrangements“). Therefore, the sanction measures now also apply to the following territories:
– 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
The new order also extends the application of the provisions provided for in sections 44, 52, and 53 of the Sanctions and Anti-Money Laundering Act 2018 to the noted Overseas Territories for purposes of the new Iran (Sanctions) Regulations 2023. Specifically, section 44 provides that persons may not be held liable for acts committed in an effort to comply with UK sanction measures, section 52 refers to the (missing) criminal liability of the Crown for compliance purposes, and section 53 preserves the prerogative powers of the crown for the purpose of designations.
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The new Iran (Sanctions) Regulations 2023 (SI 2023/1314) set out a sanctions framework to provide for financial and trade restrictions towards (legal) persons engaged in human rights violations or any „hostile activity against the United Kingdom and other countries“ in Iran. They further set out generally exempt (financial) transactions, stipulate provisions for granting a license, and define enforcement and designation powers, among others (please refer to EventID 24209 for more detailed, comprehensive information).