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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:

Supporting documents

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