Financial Sanctions: Russia General Licence

Friday, 20 May 2022

General licence - IOM/2022/RUS020

The Treasury has the power to issue General Licences for financial and trade sanctions regimes under a number of Regulations.

On 18 May 2022, the Treasury issued General licence - IOM/2022/RUS020 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”).

Any persons intending to use General Licence IOM/2022/RUS020 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/RUS020 payments and other permitted activities activities to take place in relation to winding down activities, basic needs and insolvency proceedings associated with the Amsterdam Trade Bank N.V or a subsidiary of the same. The licence will expire on 12 May 2023.

For the purposes of General Licence IOM/2022/RUS020 The Amsterdam Trade Bank N.V is a majority owned subsidiary of Alfa-Bank JSC which is a person designated under Regulation 5 of the Russia Regulations; a Subsidiary is any entity owned or controlled by the Amsterdam Trade Bank N.V; 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/RUS020:

  • The Amsterdam Trade Bank N.V may make payment for its basic needs including: payment of remuneration, allowances or pensions of employees; payment of tax; payments to suppliers of goods and services;
  • Subject to the conditions in the licence any Person (including, for the avoidance of doubt, the Amsterdam Trade Bank N.V and a Subsidiary) may make, receive or process any payments, or take any other action, in connection with any Insolvency Proceedings relating to the Amsterdam Trade Bank N.V; and
  • a Person (other than the Amsterdam Trade Bank N.V or a Subsidiary) may wind down any transactions to which it is a party, involving the Amsterdam Trade Bank N.V or a Subsidiary including the closing out of any positions and the restructuring of loans or other debt, and a Person, Relevant Institution, ATB or a Subsidiary can carry out any activity reasonably necessary to effect this.


The permissions in General Licence IOM/2022/RUS020 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.

The General Licence takes effect from the date of issue and expires on 12 May 2023.

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.

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