Please be advised that the UK authorities have issued a 'Red Alert' on financial sanctions evasion typologies by Russian elites and enablers. The alert is available via Red Alert - Financial Sanctions Evasion Typologies: Russian Elites and Enablers (nationalcrimeagency.gov.uk).
Its purpose is to provide information from law enforcement and the legal and financial services sectors on some of the common techniques designated persons and their UK enablers are suspected to be using to evade financial sanctions. These sanctions are set out in UK regulations by The Russia (Sanctions) (EU Exit) Regulations 2019 (S.I. 2019/855) made under the Sanctions and Anti-Money Laundering Act 2018 (the Sanctions Act).
The alert is not directly applicable to the Isle of Man. However, as the The Russia (Sanctions) (EU Exit) Regulations 2019 are given effect within the Isle of Man by the Russia Sanctions (Application) Regulations 2020 [S.D. 2020/0504], the typologies in the alert may be helpful to persons in the Isle of Man in identifying possible sanctions evasion activity. Businesses are therefore advised to familiarise themselves with the content of the alert.
Financial institutions and other persons are required to check whether you maintain any accounts or otherwise hold funds or economic resources for, or provide financial services to, designated individuals. If so, you must freeze such accounts or other funds and, unless licensed by the Treasury, not deal with those funds or economic resources, make those funds or economic resources available to a designated person, or make those funds or economic resources available for the benefit of a designated person. You must also report your findings to the FIU.
Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.
Where a relevant institution has already reported details of accounts, other funds or economic resources held frozen for the designated person, you are not required to report these details again.
Further details of the sanctions regime related to Russia and links to other financial sanctions regimes may be found on the Customs and Excise pages of the Isle of Man Government website.
