The Ministry of Justice this week hosted a high-level, three-day sanctions preparedness training in Gibraltar, delivered by leading UK sanctions specialists Sanctions SOS. The tabletop exercise brought together key public sector stakeholders, including the Gibraltar Financial Intelligence Unit, Gibraltar Port Authority, Borders and Coastguard Agency, HM Customs, Royal Gibraltar Police, Gibraltar Maritime Administration, Civil Status and Registration Office, Civil Aviation Authority, Government Law Offices, Financial Services Commission, Gambling Division, Legal Services Regulatory Authority and the Office of Fair Trading.

The training tested Gibraltar’s operational readiness through a complex case study with various injects that developed over the three days, designed to challenge and strengthen inter-agency coordination and response under evolving sanctions regimes. Each stakeholder impacted by the developing scenario was required to provide a step-by-step account of the actions they would take, ensuring clarity of roles, responsibilities, and decision-making processes across the public sector.  Since sanctions can affect a wide range of agencies, some of the partners involved are not traditionally part of anti-money laundering or counter-terrorism efforts. Taking time to explain each participating agency’s role helped in understanding the mechanisms, authorities, boundaries and remits in place.

Sanctions are restrictive measures that can be put in place to fulfil a range of purposes. However, they are no longer limited to freezing assets or restricting financial transactions. Their reach spans trade restrictions, maritime controls, export licensing, travel bans, and more, impacting sectors ranging from border management to port operations and financial services. As such, effective implementation demands a unified approach, where clear communication, legal clarity, and rapid response are essential.

The Minister for Justice, the Hon Nigel Feetham KC MP, who formally opened the training event, said: "Sanctions is a complex and fast-evolving area, particularly in response to the changing geopolitical landscape. We work very hard to ensure Gibraltar meets international standards on sanctions and financial crime. The purpose of this exercise is not only to identify any gaps in our system, but to ensure they are resolved, so that we have an effective, coordinated system and set of operating procedures capable of responding effectively to global threats."

This tabletop exercise is a key component of Gibraltar’s ongoing efforts to strengthen its sanctions framework, demonstrating the jurisdiction’s proactive commitment to continuous improvement, inter-agency collaboration, and alignment with international standards.