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.

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
• Humanitarian assistance

Each sanctions regime has its own licensing grounds – please consult the specific guidance for further information.

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:

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

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

External Links

The UK Government has published some further detailed guidance documents that explain key aspects to licencing. The Isle of Man takes into consideration UK licensing principles and the below documents can be used as extra guidance but where there are references to UK government departments, please look at Isle of Man guidance documents for its equivalent:

General Licences

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.

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.

Treasury's approach to General Licences

The Treasury does not automatically replicate UK General Licences; however, if you believe an equivalent Isle of Man General Licence is necessary to prevent you from being at a disadvantage please contact us. Consideration will be given to the circumstances, and a licence proposed where appropriate.

Certain UK General Licences are designed to enable the UK Government greater flexibility in handling licence applications, particularly in instances where there are numerous individual licence applications for the same type of permission. In such cases, equivalent licences are not issued by the Isle of Man, as a licensing ground already exists within the law and applicants can apply for an individual sanctions licence rather than reliance on a General Licence.

A list of current general licences issued by the Treasury can be found below.