Automatic implementation of UK Sanctions on Russia
A new amendment was made to the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 allowing automatic implementation of certain future amendments to the UK’s Russia (Sanctions) (EU Exit) Regulations 2019 on 29 September 2022.
Effects in Jersey
The amended Russia sanctions regime in Jersey means:
If the UK amends their Russia Regulations to add a new prohibition or obligation, a breach of which is a criminal offence in the UK, then the existing Jersey offence of breaching implemented sanctions provisions (carrying imprisonment for up to 7 years and an unlimited fine) will apply automatically to a breach of that new prohibition or obligation in Jersey. There will be no need for a new Jersey Sanctions Order.
If the UK grants a general licence under the UK Russia Regulations in relation to something other than an asset-freeze, then that general licence (and any conditions imposed on it by the UK) will have automatic effect in Jersey.
The Minister retains the power to modify or disapply a particular UK prohibition, obligation or license by amending the Sanctions Order or publicising a notice. Further information can be found on the Jersey Gazette.
All supervised persons are obligated to monitor relevant UK sanctions legislation, implement sanctions screening and have adequate policies, controls and procedures in place to effectively identify and mitigate risks the business faces, including appropriately identifying and dealing with sanctioned entities.
You should keep your supervisor informed of any potential sanctions breaches and if required, submit an asset-freeze application form and/or the suspected sanctions compliance reporting form.