The Treasury has the power to issue General Licences for financial and trade sanctions regimes under a number of Regulations.
On 6 July 2022, the Treasury issued General Licence IOM/2022/RUS025 under regulation 64 of the Russia Sanctions (EU Exit) Regulations 2019, as they apply to the Isle of Man by the Russia Sanctions (Application) Regulations 2020 [SD 2020/0504] ('the Regulations').
On 1 August 2022 General Licence IOM/2022/RUS025 was extended for a period of 2 months to the 30 September 2022, allowing for the winding down of postions involving Rosbank.
Any persons intending to use General Licence IOM/2022/RUS025 should consult the copy of the Licence for full details of the permissions and usage requirements which can be found attached to this release.
General Licence IOM/2022/RUS025 which allows for an extended wind down period until 30 September 2022 of positions involving Rosbank PJSC (Rosbank) or any entity owned or controlled by Rosbank.
Rosbank is owned or controlled by Vladimir Potanin who was designated on 29 June 2022 under the Russia Regulations.
For the purposes of General Licence IOM/2022/RUS025 the designated entity is:
- Rosbank PJSC
A Subsidiary is any entity owned or controlled by Rosbank; a Person is an individual, a body of persons corporate or unincorporate, any organisation or any association or combination of persons; and a Relevant Institution is:
- a person who is licensed under the Financial Services Act 2008 (of Tynwald) to carry on a regulated activity within the meaning of section 3 of that Act
- a person who is authorised or registered under the Insurance Act 2008 (of Tynwald) or holds a permit under that Act
- a person who is registered under the Moneylenders Act 1991 (of Tynwald) to carry on the business of lending money
- a person who is acting as a trustee or an administrator of a retirement benefits scheme within the meaning of the Retirement Benefits Schemes Act 2008 (of Tynwald)
Under General Licence IOM/2022/RUS025 a Person (other than Rosbank or a Subsidiary) may wind down any transactions to which it is a party, involving Rosbank or a Subsidiary including the closing out of any positions, repayment of loans, withdrawal of deposits and closing of accounts, and a Person, Relevant Institution, Rosbank or a Subsidiary can carry out any activity reasonably necessary to effect this.
The permissions in General Licence IOM/2022/RUS025 do not authorise any act which will result in funds or economic resources being made available in breach of The Russia Regulations, save as permitted under licences granted under The Russia Regulations.
The General Licence takes effect from the date of issue and expires on 30 September 2022.
Further details of the sanctions regime related to Russia may be found on the Customs and Excise pages of the Isle of Man Government website.