ASK MAT – can you outline Jersey’s annual reporting requirement for frozen assets and other such matters

ASK MAT – can you outline  Jersey’s annual reporting requirement for frozen assets and other such matters

Mat says - Here’s a summary of Jersey’s annual reporting requirement for frozen assets and a bulletin draft for local firms:

Key Points from Jersey Guidance

• Legal Basis:
  The obligation comes from the Sanctions and Asset-Freezing (Jersey) Law 2019 (SAFL) and the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021, which implements UK sanctions in Jersey. [gov.je]
• Who Must Report:
  Any Relevant Financial Institution (as defined in SAFL) that knows or suspects it holds funds or economic resources for a designated person must report to the Minister for External Relations. [gov.je]
• Annual Reporting Deadline:
• Report must be submitted by 31 October each year for assets held as of 30 September.
• Use the Immobilised Assets Reporting Form and send it to sanctions@gov.je. [gov.je]
• Scope:
  Applies to all designated persons under UK and UN sanctions implemented in Jersey, including those associated with the Russian and Belarusian regimes.
  Additional reporting obligations exist for specific sectors (e.g., oil price cap compliance). [jerseyfsc.org]
• Impact of UK Changes:
  From 28 January 2026, the UK will move to a single UK Sanctions List (UKSL). Jersey firms should update screening systems accordingly. [gov.je]

Annual Reporting Obligation = 31 October

Under the Sanctions and Asset-Freezing (Jersey) Law 2019, firms that hold or suspect they hold funds or economic resources for a designated person must:

• Submit an annual report to the Minister for External Relations by 31 October each year.
• Report covers assets held as of 30 September.
• Use the official Immobilised Assets Reporting Form and email it to sanctions@gov.je.

Who Must Report?

• Banks, trust companies, investment firms, and any entity classified as a Relevant Financial Institution under SAFL.
• Applies to all sanction regimes implemented in Jersey, including Russia, Belarus, Iran, DPRK, and others.

Additional Notes

• Event-driven reporting remains mandatory: notify the Minister immediately if circumstances change (e.g., new assets discovered, designation changes).
• Screening Update: Prepare for the UK’s transition to the UK Sanctions List (UKSL) by 28 January 2026. Update systems and vendor arrangements accordingly.

Forms & Guidance:

• Immobilised Assets Reporting Form https://www.jerseyfsc.org/industry/international-co-operation/sanctions/sanctions-forms-for-licences-and-suspected-breach-notifications/
• Sanctions Guidance – Government of Jersey - https://www.gov.je/gazette/pages/AnnualReportingRequirementsRussia-Regime.aspx

OTHER NOTES TO REMBER

1. Immediate and Continuing Duties

Under the Sanctions and Asset-Freezing (Jersey) Law 2019 (SAFL) and related Orders:

• Freeze assets without delay: You must ensure that any funds or economic resources owned, held, or controlled by a designated person remain frozen. No dealings or making assets available (directly or indirectly) are allowed unless licensed by the Minister. [altair.je]
• Maintain controls and records: Keep documented evidence of the freeze, decision-making, and any communications with the Minister. This includes audit trails for compliance checks. [jerseyfsc.org]

2. Ongoing Reporting Obligations

• Further Information Requests: The Minister can require additional details about the frozen assets at any time. You must respond promptly. [altair.je]
• Annual Reporting: Jersey follows the UK model—persons holding frozen funds or economic resources for a designated person must submit an annual report to the Minister (via the Financial Sanctions Implementation Unit). The current UK deadline is 30 November for assets held as of 30 September, and Jersey mirrors this expectation. [gov.je]
• Event-Driven Reporting: If circumstances change (e.g., asset value changes, new assets discovered, or designation status changes), you must report “as soon as practicable.” Partial disclosures are acceptable initially, followed by full details later. [altair.je]

3. Self-Reporting for Designated Persons

If you are a designated person or act for one:

• You must self-report any funds or economic resources over £10,000 to the Minister, including Jersey-situs and worldwide assets, if you are ordinarily resident or incorporated in Jersey. [comsuregroup.com]

4. Ongoing Monitoring

• Screening Updates: Continue screening against the UK Sanctions List (UKSL), as Jersey sanctions mirror UK designations. From 28 January 2026, the UKSL will replace the OFSI Consolidated List, so systems must be updated accordingly. [gov.je]
• Policy and Training: Maintain up-to-date sanctions policies, staff training, and independent audits to ensure compliance with evolving regimes. [comsuregroup.com]

✅ Practical Next Steps for You

• Confirm you have submitted the initial freeze report and diarise the annual reporting deadline.
• Review your internal sanctions policy to ensure it covers:
• Event-driven reporting triggers
• Audit trail requirements
• Escalation procedures for new designations
• Update screening systems for the UKSL transition.

Sources

Sanctions Compliance Obligations | Altair https://www.altair.je/news-insights/sanctions-compliance-obligations/

https://www.jerseyfsc.org/industry/international-co-operation/sanctions/financial-sanctions-practical-guidance/

https://www.gov.je/gazette/Pages/SanctionsUpdateLatestnewsonsanctionsimplementationinJersey.aspx