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Sally Penrose is a partner in the Corporate department of Appleby’s Bermuda office and leads the Bermuda Regulatory practice. She advises clients on a wide range of regulatory and licensing issues including financial institutions, global corporations and professional and public bodies. Sally is a leading advisor on economic substance issues and has been actively involved in the Economic Substance Task Force established by the Minister of Finance.

Sally has wide corporate experience acting for corporate and management teams on multi-jurisdictional mergers, joint ventures and acquisitions. Sally is a member of Appleby’s global Technology & Innovation group, providing comprehensive advice in connection with all aspects of digital asset issuances and the carrying on of digital asset business.

Work Highlights

  • Appleby Bermuda advised in connection with the $13.3 billion take-private acquisition of Bermuda-based Triton International Limited (Triton) by Brookfield Infrastructure Partners L.P (BIP) through BIP’s subsidiary Brookfield Infrastructure Corporation (BIPC) and its institutional partners (Brookfield Infrastructure);
  • Appleby acted as special Bermuda counsel to the noteholders in connection with the acquisition by Connor, Clark & Lunn Infrastructure of a 49.9% minority interest in Bermuda Skyport Corporation Limited from Aecon Group Inc. (Aecon), the concessionaire for the L.F. Wade International Airport;
  • VIRGIN CRUISES INTERMEDIATE LIMITED – Appleby acted as special Bermuda counsel to Virgin Cruises Intermediate Limited and represented various Virgin Voyages affiliated companies in Bermuda (VV Group), in respect of a $550 million capital raise. The funding round was led by funds managed by the Private Equity Group of Ares Management (Ares), a global alternative investment manager, and also included additional capital from existing investors including Virgin Group and Bain Capital;
  • GLOBAL ATLANTIC, – Appleby Bermuda advised Global Atlantic in its $2.4 billion capital raise for sidecar Ivy II;
  • MEANWHILE, – Appleby acted as Bermuda counsel in the establishment of Meanwhile Services (Bermuda) Limited. Meanwhile is an innovative insurer licenced as Class ILT in the Bermuda Monetary Authority (BMA) Sandbox, a testing ground for innovation;
  • COINZOOM, INC., Advised CoinZoom, Inc. on its application for a Class M Digital Asset Business licence pursuant to the Digital Asset Business Act 2018;
  • ST ENERGY TRANSITION I LTD., Appleby acted as Bermuda counsel to ST Energy Transition I Ltd. (the “Company”) on its USD250 million ESG-related SPAC IPO on the New York Stock Exchange targeting energy transition and clean energy technology;
  • INTEGRAL ILS LTD., Advised Integral ILS Ltd., in connection with a significant cornerstone investment from alternative investment manager New Holland Capital (NHC), bringing secured commitments up to $600 million;
  • STABLE GROUP, Acted as Bermuda counsel for the Stable Group in the structuring, establishing and licensing of its subsidiaries: Stable Corporation and Stable Bermuda;
  • INTEGRAL ILS LTD., Advised Integral ILS Ltd., an independent alternative fund manager focused on insurance-linked strategies in connection with a significant cornerstone investment;
  • BITTREX GLOBAL, Advised Bittrex Global on their successful application for a Class F Digital Asset Business License which represents the third such license issued by the Bermuda Monetary Authority;
  • PROSPERITY LIFE ASSURANCE LIMITED., Acted in connection with the formation and registration of Prosperity Life Assurance Limited as a Class E insurer pursuant to the Insurance Act 1978, as amended;
  • STABLEHOUSE, Acted as counsel to Stablehouse in connection with its application for a Class M Licence;
  • XBTO, Advised on the successful application for a Digital Asset Business (DABA) Licence as a Digital Asset Service Vendor (Market maker for digital assets) under the Digital Asset Business Act which represented the third DABA licence to have been issued by the Bermuda Monetary Authority;
  • BELMOND LTD., Advised Belmond Ltd. on its acquisition by LVMH Moët Hennessy Louis Vuitton SE (LVMH);
  • VALIDUS HOLDINGS LTD., Advised Validus on its $5.6 billion acquisition by American International Group, Inc.  Appleby demonstrated the strength and depth of its corporate team on this transaction with a combination of specialist M&A and regulatory lawyers forming the deal team;
  • ORION MINE FINANCE, Advised Orion Mine Finance and Fusion Capital on the sale of Lynx Resources, the owner of the SASA zinc, lead and silver mine in the Republic of Macedonia, for USD 402.5m to Central Asia Metals (“CAML”);
  • TRITON CONTAINER INTERNATIONAL LIMITED., Advised on TCIL’s merger with TAL International Group, Inc., a NYSE-listed, US company (TAL). The transaction will create the world’s largest lessor of intermodal freight containers with revenue generating assets of $8.7 billion;
  • L.F. WADE INTERNATIONAL AIRPORT – THE FINANCIAL INVESTORS, Advised on the Bermuda law relating to the financing of the redevelopment of the L. F. Wade International Airport in Bermuda (Redevelopment) pursuant to which the clients subscribed for USD 285 million of fixed coupon notes;
  • VIRGIN GROUP INVESTMENTS LTD., Advised the investment arm of billionaire Richard Branson’s family, in connection with new cruise industry venture by designing and constructing two new world class cruise ships. The lead co-investor in the deal was Bain Capital, one of the world’s leading private equity firms;
  • CHINA MINSHENG INVESTMENT CO. LTD., Advised in the acquisition of the entire issued share of capital of Sirius International Insurance Group, Ltd. The transaction was one of the largest private acquisitions in the Bermuda reinsurance space;
  • KEYTECH LIMITED., Advising in connection with a multi-layered transaction that included the acquisition of the remainder of Bermuda Digital Communications Ltd. (CellOne) and the acquisition by Atlantic Tele-Network, Inc., of a controlling interest in Keytech;
  • TRITON CONTAINER INTERNATIONAL LIMITED., Advised in relation to its merger with TAL International Group, Inc., a NYSE-listed, US company.  The transaction creates the world’s largest lessor of intermodal freight containers with revenue generating assets valued at  $8.7 billion;
  • Advised a world’s leading mining focused private equity group on their $300m+  investment; and
  • Advised on the structuring, formation and launch of a $2bn+ investment fund.


Sally is recognised by Legal 500 Caribbean as a ‘Leading Individual’ in the tier 1 Regulatory and Compliance category. She is also recognised in IFLR1000 in the Financial and Corporate category as a ‘Rising Star’.

Coverage & Insights

Qualifications & Education

  • University College London (England)
  • College of Law (London, England)

Memberships & Associations

Sally is a member of the Registrar of Companies working group responsible for drafting the economic substance guidance notes.

Sally is chair of the legal focus group (subcommittee of the Bermuda Business Development Agency) driving legislative change in the jurisdiction and is frequently invited to join working groups formed by the Island’s regulator, the Bermuda Monetary Authority.


The Legal 500

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