Sanctions
Sanctions are legal measures imposed by the UN, UK, EU, or Gibraltar to achieve specific policy or security objectives. Gibraltar has effectively implemented sanctions for many years, and the Sanctions Act 2019 contains provisions, including the automatic recognition and enforcement of UN, UK, and EU sanctions. Targeted financial sanctions serve as a preventive tool and a powerful alternative to prosecution when evidence falls short of meeting the criminal threshold.
Additionally, the potential for sanctions to be lifted acts as a strong incentive for designated individuals or entities to alter their behaviour. The Sanctions Act 2019 and the Terrorist-Asset Freezing Regulations 2011 also allow for Gibraltar-specific sanctions designations by the relevant authorities, if needed. Sanctions are most effective when applied swiftly and on a global scale, and any such designations will be posted on this page.
Currently, there are no designations in place, but notifications of Sanction Notices are sent to all THEMIS users via the Notice Board.
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The United Kingdom automatically implements United Nations sanctions. For the latest financial sanctions targets by regime, implemented by the UK's HM Treasury's Office of Financial Sanctions Implementation (OFSI) please click here.
More Information
Enquiries relating to asset freezing or other financial sanctions should be submitted to the Competent Authority.
Specific exemptions and licensing powers are generally contained in financial sanctions legislation and can allow otherwise prohibited transactions to take place in some circumstances. A licence is a written authorisation from Gibraltar competent authority permitting an otherwise prohibited act, which can be requested from the Competent Authority.
Reports of frozen funds and economic resources, information regarding a designated person, and notifications of credits to frozen accounts should be submitted to the Competent Authority using the Sanctions Reporting Form.
Reports regarding suspected breaches should be submitted in the same manner.
Sanctions Licences
The Gibraltar competent authority can issue licences under section 10 (and any regulations made under section 31) of the Sanctions Act 2019 where there are specific and relevant licensing grounds enabling it to do so, and where the conditions on those grounds have been met.
For sanctions exemption licence applications, contact the competent authority at sanctions.licence@gibraltar.gov.gi.
Sanctions Guidance
Sanctions Reporting
Under the Sanctions Act 2019, all funds or economic resources owned, held, or controlled by a designated person must be frozen. Relevant firms must report to the competent authority, as soon as practicable, the nature and amount or quantity of any such assets they hold.
Suspected breaches of financial sanctions, including failures to freeze assets or comply with reporting obligations, must also be reported promptly.
Reporting such breaches protects the integrity of the sanctions regime and supports the efforts of government and law enforcement agencies in tackling serious crime. Reporting entities should use the form below for submitting information on frozen assets and suspected breaches.
Please note that you are not required to submit a suspicious activity report to the GFIU via Themis unless you have a suspicion of Money Laundering, Terrorist Financing or Proliferation financing or other criminal conduct.
