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Jersey Update on Russia Sanctions Reporting Obligations


The Minister for External Relations ("MER") (the competent authority for sanctions enforcement in Jersey) has updated reporting requirements for RELEVANT FINANCIAL INSTITUTION and DESIGNATED PERSONS in Jersey and as follows.

  1. Regulation 16 of Russia (Sanctions)(EU Exit) (Amendment) (No. 4) Regulations 2023, [] as reflected in Jersey law according to the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021, requires Relevant Financial Institutions to report to the MER as soon as reasonably practicable
    1. A "Relevant Financial Institution" is:

                      i. A person [natural or legal] carrying on a financial services business in or from within Jersey, or a person [not being an individual] incorporated or constituted under the laws of Jersey and carrying on financial service business in any part of the world.

  1. Regulation 16 states that Relevant Financial Institutions must report to MER as soon as reasonably practicable if:
    1. It knows or has reasonable cause to suspect it holds funds or economic resources for a prohibited person (i.e. a person designated by Regulation 18A of the UK Russia Sanctions Regulations 2019 -  ); and
    2. The information or other matter on which the knowledge or cause for suspicion is based came to it in the course of carrying on business.
  2. Regulation 17 of Russia (Sanctions)(EU Exit) (Amendment) (No. 4) Regulations 2023 requires a DESIGNATED PERSON to self-report to MER any funds or economic resources over the value of £10,000.
    1. This relates to Jersey situs or worldwide assets (if they are ordinarily resident in Jersey [individual] or incorporated or constituted under the laws of Jersey).

The above 16+17 supplement the existing duty on Relevant Financial Institutions under Article 32 of the Sanctions and Asset-Freezing (Jersey) Law 2019 [] to report to MER as soon as practicable if:

  1. It holds an account of a person, has entered into dealings or an agreement with a person or has been approached by or on behalf of a person.
  2. It knows or has reasonable cause to suspect that the person –
    1. Is a designated person or
    2. Has committed, is committing or intends to commit an offence under this Law; and
  3. The information or other matter on which the knowledge or reasonable cause for suspicion is based came to it while carrying on its business.



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