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Bermuda Sanctions Regime Post Brexit

As a British Overseas Territory, Bermuda generally implements the same international sanctions as the United Kingdom. Bermuda relies on the UK’s framework for sanction implementation, which is provided in the form of Overseas Territories Orders in Council (OT Orders). However, unlike other overseas territories, OT Orders do not automatically come into force in Bermuda when they are passed in the UK – they must be brought into force domestically in Bermuda.

Prior to Brexit, the UK implemented sanctions via European Union decisions and regulations, which meant that Bermuda’s sanctions regime also mirrored that of the European Union. Post Brexit, the UK is implementing sanctions autonomously and differences may arise between the UK and EU regimes. As Bermuda’s sanctions regime will continue to mirror that of the UK, it should no longer be assumed that there will be no difference between Bermuda sanctions and EU sanctions.

Sanctions are given effect in Bermuda by the International Sanctions Act 2003, the International Sanctions Regulations 2013 and the International Sanctions Amendment Regulations 2020 (“Sanctions Regulations”). Schedule 1 of the Sanctions Regulations lists every sanctions-related OT Order issued by the UK and currently in force in Bermuda; it is amended regularly as new measures are extended and existing ones repealed. Most of the existing OT Orders contained in Schedule 1 of the Sanctions Regulations were repealed and replaced with new OT Orders brought into force in November and December 2020.


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Bermuda Sanctions Regime Post Brexit


Julie E. McLean

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