Sanctions and Export Control

The Customs and Immigration Division is the competent authority for sanctions in the Isle of Man. The Division:

• Implements United Nations and United Kingdom sanctions legislation
  
  
• Publishes sanctions designation updates and guidance
  
  
• Provides outreach to promote compliance and prevent breaches of sanctions law
  
  
• Processes applications for, and issues, sanctions licences
  
  
• Works in partnership with other government agencies to monitor compliance with sanctions legislation
  
  
• Enforces sanctions law in the Isle of Man in conjunction with the Isle of Man Constabulary

An overview of the Customs and Immigration Division can be found on the below page:

What are sanctions

Sanctions are prohibitions and restrictions on trade and services, which may be put in place by the United Nations ('UN') and at a national level by countries, acting alone or together with others, with the aim of maintaining or restoring international peace and security. They generally target specific individuals or entities, or particular sectors, industries or interests. They may be aimed at people in a particular country or territory, or some organisation or element within them. Sanctions may also impose restrictions on goods and services supplied to or from a country or territory. There are also sanctions to target those persons and organisations involved in terrorism, including Al-Qaida and ISIL.

Sanctions are generally imposed to:

• Coerce a regime, or individuals within a regime, into changing their behaviour (or aspects of it) by increasing the cost on them to such an extent that they decide to cease the offending behaviour
  
  
• Constrain a person or group of persons by denying them access to key resources needed to continue their offending behaviour, including the financing of terrorism or nuclear proliferation
  
  
• Signal disapproval, stigmatising and potentially isolating a regime or individual, or as a way of sending broader political messages nationally or internationally
  
  
• Protect the value of assets that have been misappropriated from a country until these assets can be repatriated

What is a sanctions regime

In response to a situation of international concern, the UN Security Council, or an individual country or group of countries, may impose what is referred to as a sanctions ‘regime’. Each regime is usually described by reference to a country or thematic group. Changes are regularly made to sanctions regimes. The Isle of Man imposes the following sanctions regimes:

• UN sanctions (made by UN Security Council Resolutions)
  
  
• UK sanctions (made by Regulations under the Sanctions and Anti-Money Laundering Act 2018)
  
  
• Designations relating to terrorism (made under the Terrorism and Other Crime (Financial Restrictions) Act 2014)

It is the policy of the Isle of Man Government to maintain the implementation of international sanctions measures in the Isle of Man in line with such measures as have effect in the United Kingdom from time to time. Financial, trade, transport and immigration sanctions are implemented in the United Kingdom by Regulations under the Sanctions and Anti-Money Laundering Act 2018. The Isle of Man, through the United Kingdom’s membership of the United Nations, is also obliged to implement sanctions measures imposed by UN Security Council resolutions, and in particular in relation to the prevention and suppression of terrorist financing and proliferation financing.

What are the different types of sanctions

There are a range of different types of sanctions measures that can be imposed against a country or group. These include:

Financial

• Targeted asset freeze
  
  
• Restrictions on investment and financial services

Trade

• Arms embargoes
  
  
• Import/export restrictions on goods and technology
  
  
• Restrictions on provision or procurement of services relating to goods and technology
  
  
• Restrictions on the provision or procurement of certain other non-financial services

Transport

• Restrictions on ship and aircraft movements
  
  
• Restrictions on ownership or registration of ships and aircraft

Immigration

• Travel bans

Do I need to comply with Sanctions

Sanctions apply more broadly than simply to the persons subject to them. The following outlines where sanctions apply and who needs to comply with them:

• Sanctions apply within the territory of the Isle of Man and to all Island persons (i.e. individuals normally resident in the Island and legal entities established in the Island), wherever they are in the world
  
  
• All individuals and legal entities who are within or undertake activities within the Island’s territory must comply with the sanctions that are in force. For example, this includes corporate service providers, banks, the insurance sector etc.
  
  
• All Island persons (including corporate branches), must also comply with the sanctions that are in force, irrespective of where their activities take place

It is prohibited to intentionally participate in any activities if you know that the object or effect of them is to circumvent the sanctions imposed or to enable or facilitate the contravention of those prohibitions. If you are unclear about any aspects of sanctions law, in particular about whether action you are considering taking could contravene the law, you are advised to seek independent legal advice.

How do I find out who is subject to sanctions

There are Sanctions Lists that provide information on who is subject to sanctions.

Contact Us

Address:

Ground Floor,
Government Offices,
Bucks Road,
Douglas,
Isle of Man,
IM1 3PN

Contact the Sanctions Team on:

Telephone: +44 1624 648109

Email: sanctions@gov.im

PLEASE NOTE: We are unable to provide legal advice. You may need to seek independent legal advice.

Public Counter Hours

Monday to Friday: 10am to 2pm

You are encouraged to make appointments before visiting and they can also be arranged outside of counter opening hours on request.

The counter may occasionally be closed for staff training or operational matters. Notifications will be put up giving sufficient notice.

Privacy Notice

The Treasury collects information about you in order to administer taxation and carry out other functions for which it is responsible (e.g. National Insurance, customs and excise duties, property rates, social security benefits, state pensions and legal aid etc.), and for the detection and prevention of crime.

Whilst that information will primarily be provided by you, where the law allows, we may also get information about you from other organisations or give information about you to them. This may be to check the accuracy of the information provided, prevent or detect crime or protect public funds in other ways. These organisations may include other government departments, the police and other agencies.

To find out more about how we collect and use personal information, contact any of our offices or visit our website.