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Sanctions General Licence: Russia

Wednesday, 7 December 2022

Further to the amendments to the Russia Sanctions consolidated legislation on 5 December 2022, the Treasury advises that four general licences have been issued.

The amendments on 5 December 2022 prohibited the import, acquisition, supply and delivery of Russian oil and oil products, that fall in to the commodity code headings 2709 and 2710 in the UK Tariff, into the IOM and UK. Ancillary services in repect of those activities were also prohibited.

They also banned the supply or delivery by ship of oil and oil products originating in or consigned from Russia, from a place in Russia to a third country, or from one third country to another third country, as well as the provision of related ancillary services (including brokering services and financial assistance). Third country means any country other than the United Kingdom, the Isle of Man or Russia.

General Licence IOM/2022/RUS035 makes IOM seaborne transportation services available to third country importers and exporters – so long as the price paid for Russian oil or oil products is at or below a price cap. The UK, in partnership with the G7 countries, Australia and the European Union, have agreed to set the price cap on Russian crude oil traded by firms shipping oil to third countries at USD$60.

Subject to the exclusions and conditions in the Licence, and provided that no supply or delivery by Ship of Russian oil or Relevant Services are provided to a Designated Person:

  • A Person may supply or deliver Russian oil by Ship from a place in Russia to a Third Country or from one Third Country to another Third Country provided that the Unit Price of the Russian oil concerned is at or below the Price Cap.
  • A Service Provider may provide Relevant Services to any Person provided that the Unit Price of the Russian oil being supplied or delivered by Ship from a place in Russia to a Third Country or from one Third Country to another Third Country is at or below the Price Cap.
  • A Relevant Institution may process payments in relation to the activities authorised by the activities above.  

There are specific conditions, reporting requirements and record keeping requirements for anyone using this licence. Please consult the licence for full details.

The General Licence takes effect from the 5 December 2022 and is for an indefinite duration.

General Licence IOM/2022/RUS036 is a wind-down licence which permits contracts to ship Russian oil traded at a point above the price cap where the Russian oil was loaded before 5 December 2022 and to be unloaded at the destination port by 19 January 2023.

Subject to the exclusions and conditions in this Licence, and provided that no supply or delivery by Ship of Russian oil or Relevant Services are provided to a Designated Person:

  • A Person may supply or deliver Russian oil by Ship from a place in Russia to a Third Country or from one Third Country to another Third Country.
  • A Service Provider may provide Relevant Services to any Person supplying or delivering by Ship from a place in Russia to a Third Country or from one Third Country to another Third Country.
  • A Relevant Institution may process payments in relation to the activities authorised by the activities above.

There are specific conditions, reporting requirements and record keeping requirements for anyone using this licence. Please consult the licence for full details.

The General Licence takes effect from the 5 December 2022 and is for an indefinite duration.

General Licence IOM/2022/RUS037, subject the the conditions in the licence, allows correspondent banking and payment processing in connection with the services provided under the other general licences.

There are specific conditions for anyone using this licence, please consult the licence for full details.

The General Licence takes effect from the 5 December 2022 and is for an indefinite duration

General Licence IOM/2022/RUS038 allows specified activities listed in schedule to the licence, regarding the supply and delivery of Russian Oil to exempt projects and Countries for a period of time.

There are permissions and record keeping requirements for anyone using this licence. Please consult the licence for full details.

The General Licence takes effect from the 5 December 2022 and is for an indefinite duration

Any persons intending to use a General Licence should consult the copy of the Licence for full details of the permissions and usage requirements. General Licences issued by the Treasury can be found on the Custom and Excise webpage.

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 Russia Regulations, save as permitted under licences granted under The Russia Regulations.

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

Further details of the sanctions regime related to Russia and links to other financial sanctions regimes may be found on the Customs and Excise pages of the Isle of Man Government website.

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