The Treasury advises that the Russia Sanctions consolidated legislation has been amended following changes to the statutory documents relating to Russia trade sanctions. These changes come into effect on 16 December 2022.
The Russia (Sanctions) (EU Exit) Regulations 2019 (of UK Parliament) (the 'Russia Regulations') were applied to the Island, and currently have effect in the Island, by the Russia Sanctions (Application) Regulations 2020 [SD 2020/0504]. The Russia Regulations have been amended in the United Kingdom in response to Russian actions in Ukraine. The Isle of Man is adopting these measures to ensure that sanctions against Russia in the Island are aligned with the United Kingdom.
The amendments provide for:
- A prohibition on providing services related to trusts or similar arrangements to, or for the benefit, of persons designated for the purposes of this measure; and on providing new services related to trusts or similar arrangements to, or for the benefit of, persons connected with Russia
- Amendments to existing restrictions on dealing with securities or money market instruments and loans and credit arrangements to persons connected with Russia to close loopholes
- An expansion of the current prohibitions on the export, supply and delivery, and making available of additional products (as well as related technical assistance, financial services and funds, and brokering services), to the critical-industry goods, critical-industry technology schedule, defence and security goods and defence and security technology schedule
- A prohibition on the direct and indirect provision of auditing services to a person connected with Russia. The measure is designed to hamper Russian businesses’ ability to operate efficiently in commercial and financial markets
- A prohibition on the direct and indirect provision of advertising services to a person connected with Russia. This measure will impact the ability of Russian business to sell its goods and services
- A prohibition on the direct and indirect provision of architectural and engineering services to a person connected with Russia. These are two separate sanctions measures, which are being imposed in tandem given these services are often used together in project lifecycles. These measures will disrupt Russia’s high-end engineering, scientific and other technical economic functions
- A prohibition on the direct or indirect provision of information technology consultancy and design services to a person connected with Russia. This measure will erode the capability of information technology systems to support the Russian economy
Limited exceptions and licensing grounds will be in place with these measures. These may include, for example, a licence to facilitate winding-down operations and exceptions for statutory obligations or diplomatic activities. The exceptions and licensing grounds are set out in full in the legislation. If you need to apply for a sanctions licence, you can find more information and how to apply on the Customs and Excise webpage.
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.