Sanctions Licences
On this page you will find out what sanctions licences are, what types of licence are available and when you might need to apply for one. Information on general licences, and how to apply for a licence can also be found on this page.
Under sanctions legislation, there are some exceptions that allow the Treasury to issue general or specific licences to permit certain acts that would otherwise be prohibited.
Licences
Overview
Under financial sanctions legislation a person must not:
- Deal with funds or economic resources owned, held or controlled (directly or indirectly) by a designated person
- Make funds available to any person for the benefit of a designated person if they know, or have reasonable cause to suspect, that they are making such funds available
This includes funds held in bank accounts, insurance policies and companies owned by designated persons. Assets must be frozen by the relevant bank, insurer, service provider etc., and must not be used, altered, transferred or access given to such assets. Such actions would be a breach of sanctions.
Under trade sanctions legislation, there are prohibitions and restrictions on trading in certain goods or services. This may include import and export bans, arms embargoes and restrictions on what services can be provided.
Sanctions licences may be issued to a person on an individual basis, where there are legal grounds for doing so. This may include (but are not limited to) the following:
- Basic needs
- Reasonable legal fees or reasonable expenses associated with legal services
- Reasonable fees for routine holding or maintenance of frozen assets
- Extraordinary expenses
- Prior obligations
Each sanctions regime has its own licensing grounds – please consult the specific guidance for further information.
General licences may be issued to allow multiple parties to undertake specified activities that would otherwise be prohibited by sanctions legislation, without the need for a specific licence.A list of current general licences can be found below.
Requirements will be stated in each general licence. If you are using a general licence it is your responsibility to ensure the activities you undertake fall within the terms of the licence and that you comply with any conditions of the licence.
How to apply for a licence
You are strongly encouraged to read the sanctions licence guidance, which provides information on licensing grounds before making an application for a licence:
You should also:
- Review the up-to-date legislation that applies in your situation
- Consider taking independent legal advice if you are unsure of your obligations
For all licence applications, you must set out the full facts and details of the licence needed. In some cases a general licence may already be in place.
Complete the application form and send it, along with supporting documentation to: Sanctions@gov.im
General Licences and General Trade Licences
Financial
Licence: Russia – Annual Returns
Licence Number: IOM/2023/RUS041
Date Issued: 16/05/2023
Regime: Russia
Licence: Russia – Law Enforcement and Regulatory Authorities Asset Recovery
Licence Number: IOM/2022/RUS018
Date Issued: 10/05/2022
Regime: Russia
Humanitarian
Licence: Syria – Earthquake Relief Efforts in Syria
Licence Number: IOM/2023/GTL002
Date Issued: 04/07/2023
Regime: Syria
Licence: Russia – Humanitarian Activity
Licence Number: IOM/2022/RUS026
Date Issued: 08/07/2023
Regime: Russia
Vessels
Licence: Russia – Vessels
Licence Number: IOM/2022/GTL001
Date Issued: 01/08/2023
Regime: Russia
Oil Price Cap
General Licences, guidance and reporting forms in relation to the Maritime Services Ban and Oil Price Cap Exception.
Licence: Russia – Oil Price Cap
Licence Number: IOM/2024/RUS042
Date Issued: 25/04/2024
Regime: Russia
Licence: Russia – Oil Price Cap: Correspondent Banking and Payment Processing
Licence Number: IOM/2022/RUS037
Date Issued: 07/12/2022
Regime: Russia
Guidance documents
The UK Government has published detailed guidance documents that explains the ban for Russian oil, oil products and the ban on the provision of maritime transportation of, and associated services for the maritime transportation of, certain Russian oil and oil products which can be found below:
Where the UK guidance or forms refers to:
- Reporting and suspected breaches - please use the method in chapter 5 of the Financial Sanctions – General Guidance instead
- Russian sanctions guidance – please use our guidance Russia Sanctions Guidance
- Contacting or submission of forms should be emailed to sanctions@gov.im
- References to general licences - please use the above licences only
Supporting documents
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