Terrorist Names, Anti-Terrorism Orders and Sanctions
Gibraltar is a member of the EU by reason of Article 355(3) of the Treaty on the Functioning of the European Union. As such, legislative acts of the EU apply to Gibraltar, with Regulations being directly applicable without the need for local transposition.
Gibraltar enacted the Sanctions Act 2019 (the Act) to update and modernise its sanctions regime. The Act provides for the automatic recognition and enforcement in Gibraltar of UN, EU and UK sanctions.
The Act (under section 62(e)) provides for sanctions imposed by the UK to be automatically recognised in Gibraltar. This means that the UK’s list of asset freeze targets, which includes UN, EU and UK sanctions, provides a very useful and up to date database of sanctioned targets that need to be acted upon by Gibraltar’s financial sector. However, Gibraltar users should be careful to ensure that they are aware of any additional targets that have been designated locally, permitted by the Act or the Terrorist Asset-Freezing Regulations 2011. Local designations can be accessed on the Gibraltar Financial Intelligence Unit (GFIU) website.
The GFIU has published a Guidance Note on Financial Sanctions which can be accessed here.
Firms are requested to check whether they maintain any accounts for the entities and/or individuals listed and, if they do, are asked to freeze the accounts and report their findings to:
Gibraltar Financial Intelligence Unit
Suite 832 Europort
Tel: (+350) 200 70211/200 70380
Fax: (+350) 200 70233
These checks are to be undertaken as part of the client take-on process, at other periodic intervals and on trigger events, throughout the duration of a client relationship, as determined by an institutions risk based approach.
Should you have any queries, you may contact the AML/CFT team on firstname.lastname@example.org or on +350 20040283.
Updated on 12 April 2019.