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Financial Sanctions: Global Human Rights Regime

Wednesday, 22 July 2020

This news release is issued to publicise a new global sanctions regime introduced to freeze the funds and economic resources of certain persons, entities or bodies responsible for or involved in serious violations of human rights. The new regime will target individuals and organisations rather than nations.

The Global Human Rights Sanctions (Isle of Man) Order 2020 (“2020 Order”) comes into operation on 22 July 2020.  This Order extends, with modifications, the United Kingdom’s Global Human Rights Sanctions Regulations 2020 (“GHR Regulations”), to the Isle of Man from 22 July 2020. The GHR Regulations are the first Regulations to come into force in the United Kingdom under the Sanctions and Anti Money Laundering Act 2018. 

The GHR Regulations establish a sanctions regime for the purpose of deterring, and providing accountability for, activities which, if carried out by or on behalf of a State, would amount to serious violations of certain human rights by that State.

The 2020 Order provides that a designated person in the UK is also a designated person in the Isle of Man. Designated persons may be excluded from the Isle of Man and may be made subject to financial sanctions, including having their funds or economic resources frozen. The list of designated persons is the same list published by the Office of Financial Sanctions Implementation:

Global Human Rights

The GHR Regulations, as they are extended to the Isle of Man, provide for certain exceptions to this sanctions regime (for example to allow for frozen accounts to be credited with interest or other earnings and to allow acts done for the purpose of national security or the prevention of serious crime). The Treasury may issue a licence in respect of activities that would otherwise be prohibited under the GHR Regulations. 

Financial institutions and other persons are requested to check whether they maintain any accounts or otherwise hold funds or economic resources for, or provide financial services to, the designated individuals and entities. If so, they must freeze such accounts or other funds and, unless licensed by the Treasury, refrain from dealing with said funds or economic resources, and suspend the provision of any financial services. They must also report their findings to the FIU. 

Failure to comply with financial sanctions legislation or to seek to circumvent its provisions is a criminal offence.

Further details of the sanctions regime related to Global Human Rights and links to the UK’s Consolidated List of individuals and entities subject to these and other financial sanctions may be found on the Customs and Excise pages of the Isle of Man Government website.

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