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Designated Persons & Delisting

Find out who is designated under financial sanctions in Bermuda, what to do if you find a match, and how a designated person can ask to be removed from a sanctions list.

What is a designated person?

A designated person is an individual, entity or body listed under UK legislation as subject to financial sanctions. UK sanctions regimes are extended to Bermuda by Orders in Council and given effect through the International Sanctions Act 2003 and the International Sanctions Regulations 2013. This means a person designated by the UK is also subject to an asset freeze in Bermuda.

Since 28 January 2026, the UK Sanctions List has been the only list of UK sanctions designations. The OFSI Consolidated List and its search tool are no longer updated. Before you transact, check both:

  1. the UK Sanctions List
  2. the Bermuda Designation List

People designated before 28 January 2026 have both an OFSI Group ID and a UK Sanctions List Unique ID. People designated since then have only a Unique ID.

Bermuda Designation List

Bermuda maintains its own list of designated persons, separate from the UK Sanctions List. There are currently no designations on the Bermuda list.

View the Bermuda Designation List

Entities owned or controlled by a designated person

Financial sanctions also apply to entities owned or controlled, directly or indirectly, by a designated person. These entities may not be listed in their own right, so their names may not appear on the UK Sanctions List. You should carry out due diligence on ownership and control, and seek legal advice if you are unsure.

What to do if you find a match

If you identify funds or economic resources owned, held or controlled by a designated person, you must:

  1. Freeze them immediately.
  2. Not deal with them or make them available, directly or indirectly, to or for the benefit of the designated person.
  3. Report to the FSIU by completing a Compliance Reporting Form.

Dealing with frozen assets is only permitted under a licence issued by the Minister of Justice, or where an exception applies. See Apply for a Bermuda asset freeze licence and Bermuda General Licences.

If you think you have been wrongly identified

Sometimes a person or business shares a name with a designated person. If your account or payment has been stopped and you believe you are not the designated person, contact the firm involved first. You may be asked for identification so they can confirm you are not a match. If the matter is not resolved, contact the FSIU at fsiu@gov.bm.

Requesting removal from a sanctions list (delisting)

Designations are made by the UK government or the United Nations, not by the Government of Bermuda. Requests to be removed from a list must be made to the authority that made the designation.

UK designations

A designated person can ask the UK government to vary or revoke their designation. Information on how to request a review is available from the UK Foreign, Commonwealth & Development Office:

https://www.gov.uk/government/publications/making-a-sanctions-challenge-how-to-seek-variation-or-revocation-of-a-sanctions-designation/making-a-sanctions-challenge-how-to-seek-a-variation-or-revocation-of-a-sanctions-designation

UN designations

Where a UK designation gives effect to a UN listing, the request must go to the UN:

  1. For the ISIL (Da’esh) and Al-Qaida sanctions regime, contact the Office of the Ombudsperson.
  2. For all other UN sanctions regimes, contact the Focal Point for De-listing.

You can also ask the UK government to request your removal from a UN list on your behalf.

We recommend seeking independent legal advice before making a delisting request.

When a person is removed from a list

When a designation is revoked, the asset freeze stops applying in Bermuda once the change takes effect under UK legislation. Before releasing any funds, check that:

  1. the person has been removed from the UK Sanctions List and is not on the Bermuda Designation List
  2. the person is not still designated under another sanctions regime
  3. the assets are not owned or controlled by another designated person

If you have reported frozen assets that are later released following a delisting, tell the FSIU. If you are unsure whether you can release funds, contact the FSIU before you act.

Subscribe to the FSIU Bermuda Sanctions Alert Subscription Service to be notified of new designations, amendments and delistings.

Source: gov.bm/articles/designated-persons-delisting
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