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Financial Sanctions: Belarus General Licence

Monday, 28 March 2022

General licence - IOM/2022/BEL003

The Treasury has the power to issue General Licences for financial and trade sanctions regimes under a number of Regulations.  Treasury licences permit acts that would normally be prohibited by the Regulations to take place, and may be general or specific in nature.  The Treasury licence outlined below corresponds to a general licence issued by HM Treasury this week, following the extension of financial and trade sanctions against Belarus. 

On 28 March 2022, the Treasury issued General Licence IOM/2022/BEL003 under regulation 32 of the Belarus (Sanctions) (EU Exit) Regulations 2019, as they apply to the Isle of Man by the Belarus Sanctions (Application) Regulations 2020 [SD 2020/0479] (“the Belarus Regulations”). Which allows for a 30 day wind down period of positions involving the DP specified below. 

Any persons intending to use any of the above General Licence should consult the copy of the Licence for full details of the permissions and usage requirements which can be found attached to this release. 

For the purposes of General Licence INT/2022/1424277 the DP is: Bank Dabrabyt Joint Stock Company. 

A Subsidiary is any entity owned or controlled by the DP; 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/BEL003 a Person (other than the DP or a Subsidiary) may wind down any transactions to which it is a party, involving the DP or a Subsidiary including the closing out of any positions, and a Person, Relevant Institution, or the DP or a Subsidiary can carry out any activity reasonably necessary to effect this. 

General 

The permissions in General Licence IOM/2022/BEL003 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 Belarus Regulations, save as permitted under licences granted under The Belarus Regulations.

General Licence IOM/2022/BEL003 takes effect from date of issue and expires on 23 April 2022.

Further details of the sanctions regime related to Belarus may be found on the Customs and Excise pages of the Isle of Man Government website.

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