The Treasury has the power to issue a General Licence for financial and trade sanctions regimes under a number of Regulations.
On 17 November 2025, the Treasury issued General Licence IOM/2025/RUS049 under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 ('the Regulations'), as they have effect in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024, which are made under the Sanctions Act 2024.
Any persons intending to use a General Licence should consult a copy of the Licence for full details of the definitions, permissions and usage requirements which can be found attached to this release.
For the purposes of the General Licence:
The Named Subsidiaries means the following subsidiaries of PJSC Rosneft Oil Company: Rosneft Deutschland GmbH, RN Refining & Marketing GmbH; and a Subsidiary.
A 'Subsidiary' means any entity owned or controlled, directly or indirectly, by the Named Subsidiaries within the meaning of regulation 7 and Schedule 1 of the Regulations (as they have effect in the United Kingdom). For the avoidance of doubt this also includes any refinery owned or controlled by the Named Subsidiaries, including, but not limited to, the PCK Schwedt refinery.
A DP means any individual or body of persons (corporate or unincorporate) designated for the purpose of section 9(2) of the Sanctions and Anti-Money Laundering Act 2018 (of UK Parliament) and/or any body of persons (corporate or unincorporate) owned or controlled directly or indirectly by that designated person as determined under the criteria set out in Regulation 7 and Schedule 1 of the Regulations (as they have effect in the United Kingdom) other than the Named Subsidiaries.
A Person means an individual or a body of persons corporate or unincorporate, any organisation or any association or combination of persons which is not itself a DP.
A Relevant Institution has the meanings given in:
(a) paragraph 2(1) of Schedule 2 of the Sanctions (Implementation of UK Sanctions) Regulations 2024 [SD 2024/0118]; and
(b) regulation 58(7) and (8) of the Regulations (as they have effect in the United Kingdom).
General Licence IOM/2025/RUS049 – Continuation of Business of PJSC Rosneft Oil Company’s German Named Subsidiaries which permits a Person to continue business operations involving the Named Subsidiaries including, but not limited to:
- Payments to or from the Named Subsidiaries under any existing or new obligations or contracts
- Payments to or from any other Person under any obligations or contracts and
- Provision of, and receipt of, economic resources from the Named Subsidiaries
- A Relevant Institution may process payments made in accordance with the terms of the General Licence
Notification and record-keeping requirements
The notification and record-keeping requirements for the DP, Persons, Relevant Institutions are set out in the general licence.
Any persons intending to use the General Licence should consult the copy of the Licence for full details of the permissions and usage requirements.
General
The permissions in General Licences do not authorise any act which the person carrying out the act knows, or has reasonable grounds for suspecting, will result in funds or economic resources being made available in breach of the Regulations, or any other regulations given effect in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024 [SD 2024/0118] save as specifically permitted under this or other licences granted by the Treasury.
Further details of the sanctions regime related to Russia may be found on the Isle of Man Government website.
