Bio

Sally Penrose heads the Bermuda regulatory practice advising clients including financial institutions, global corporations, professional and public bodies on a wide range of regulatory and licensing issues. 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 is also 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 (sub committee 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.

Sally has wide corporate experience acting for corporates 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 initial coin offerings and the carrying on of digital asset business. Sally is recognised by Legal 500 Caribbean as a ‘Next Generation Partner’ in the tier 1 Corporate and Commercial category. She is also recognised in IFLR1000 in the Financial and Corporate category as a ‘Rising Star’

RECENT ARTICLES:

Expertise:

Recent transactions include:

  • 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;
  • Advised on the structuring, formation and launch of a $2bn+ investment fund.

Education:

University College London (England)

College of Law (London, England)

“Sally Penrose possess excellent technical skills and is highly responsive and dedicated.” 

Legal 500
2020

Updates

3 Nov 2020 | Deals

Appleby Bermuda advised Integral ILS Ltd. in connection with a significant cornerstone investment

Appleby advised Integral ILS Ltd., an independent alternative fund manager focused on insurance-link...

14 Oct 2020 | News

Sally Penrose and Jennifer Parsons speak on Regulatory webinar panel to New York State Bar Association members

The New York State Bar Association is hosting a virtual webinar entitled ‘Bermuda and Cayman Islan...

Contributors: Jennifer Parsons
1 Oct 2020 | Deals

Appleby advised Bittrex Global on acquiring their Digital Asset Business License to operate their cryptocurrency exchange from Bermuda

Appleby acted as Bittrex Global GmbH’s Bermuda counsel, on their application for a Class F Digital...

16 Sep 2020 | News

Bermuda Regulatory Update: Q1 and Q2 2020

Our latest Regulatory update for Bermuda.

1 May 2020 | News

Bermuda Launches Economic Substance Declaration Portal

Today marked a significant milestone in Bermuda’s economic substance regime with the launch of the...

Contributors: Sally Penrose
15 Apr 2020 | News

COVID-19 Economic Substance Update

All of the offshore jurisdictions in which Appleby operates have implemented legislation to require ...

18 Feb 2020 | News

Bermuda Joins EU Whitelist

The Economic and Financial Affairs Council (ECOFIN) announced today that Bermuda has moved to the ...

Contributors: Sally Penrose
27 Jan 2020 | News

Appleby to Sponsor and Speak at Canadian Technology Summit in Bermuda

Appleby is pleased to be sponsoring and speaking at the Canadian Technology Summit in Bermuda the we...

20 Jan 2020 | News

Bermuda Recognised as a Global Leader in the Fight Against Financial Crime

Bermuda has made significant strides in strengthening its overall Anti-Money Laundering and Anti-Ter...

Contributors: Sally Penrose

Publications

8 Apr 2020 |

COVID-19’s impact on AGMs – Strategies to Consider

This article considers the legal and practical issues of each option to assist companies that are gr...

Contributors: Sally Penrose
1 Jul 2019 |

Latest Developments in Bermuda’s Economic Substance Regime

The Economic Substance Amendment Act 2019 (Amendment Act) became operative on 28 June 2019. Bermuda ...

Contributors: Sally Penrose
26 Jun 2019 |

Regulatory Headwinds

Faced with increased scrutiny from regulators on both global and jurisdictional levels, businesses m...

Contributors: David Dorgan

Related People

Brad Adderley

Partner: Bermuda

T +1 441 298 3243
E Email Brad

Alan Bossin

Chief Operating Officer: Bermuda

T +1 441 298 3536
E Email Alan

David Clark

Partner: Bermuda, BVI

T +1 441 298 3583
E Email David

Matthew Ebbs-Brewer

Partner, Head of Funds & Investment Services: Bermuda

T +1 441 298 3226
E Email Matthew

Tim Faries

Managing Partner: Bermuda

T +1 441 298 3216
E Email Tim

Clive Langley

Partner: Bermuda

T +1 441 298 3202
E Email Clive

Steven Rees Davies

Partner, Joint Global Head of Technology & Innovation: Bermuda

T +1 441 298 3296
E Email Steven

Matthew Carr

Counsel: Bermuda

T +1 441 298-3594
E Email Matthew

Jennifer Eve

Counsel: Bermuda

T +1 441 298 3560
E Email Jennifer

John Small

Associate: Bermuda

T +1 441 298 3595
E Email John

Larissa Roche

Associate: Bermuda

T +1 441 298 3258
E Email Larissa

Jamie Rego

Senior Associate: Bermuda

T +1 441 298 3562
E Email Jamie

Josephine Noddings

Senior Associate: Bermuda

T +1 441 298 3553
E Email Josephine

Andrew Kuzma

Senior Associate: Bermuda

T +1 441 298 3222
E Email Andrew

Neil Molyneux

Senior Associate: Bermuda

T +441 298 3558
E Email Neil

Tiffany Boys

Counsel: Bermuda

T +1 441 298 3596
E Email Tiffany

Tonesan Amissah

Managing Director: Bermuda

T +1 441 298 3302
E Email Tonesan