Update

Black Swan has its wings clipped

For the past 10 years the courts of the British Virgin Islands have regularly granted freezing orders under the so-called Black Swan jurisdiction in support of foreign proceedings against non-cause of action defendants located in the BVI, holding assets against which any foreign judgment might ultimately be enforced. The Eastern Caribbean Court of Appeal has however recently held that the BVI courts have no jurisdiction, absent statutory authority, to grant interlocutory injunctions in aid of proceedings in a foreign country.