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Financial Sanctions: Russia General Licence RUS031

Thursday, 10 November 2022

General licence - IOM/2022/RUS031

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

On 09 November 2022, the Treasury issued General Licence IOM/2022/RUS031 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 Russia Regulations”).

Any persons intending to use General Licence IOM/2022/RUS031 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/RUS031 pertains to Securing Energy for Europe, otherwise known as Gazprom Germania, and its subsidiaries, including SEFE Marketing and Trading and SEFE Energy.  

For the purposes of General Licence IOM/2022/RUS031, a category 5 loan has the same meaning as in Regulation 17 of the Russia Regulations.

General Licence IOM/2022/RUS031 allows for the continued granting of category 5 loans or entering into arrangements to grant category 5 loans with Gazprom Germania and/or its subsidiaries.

General Licence IOM/2022/RUS031 also permits persons to carry out any activity necessary for the granting of category 5 loans. The General Licence contains a non-exhaustive list of purposes for which loans may be granted, including:

  1. over the counter trading in gas and power market trades

  2. payment in respect of credit arrangements and invoices by Gazprom Germania and/or any of its Subsidiaries to any third party for purchase of gas or services

  3. customer credit arrangements/any arrangements by customers to make prepayments to Gazprom Germania and/or any of its Subsidiaries

  4. provision of clearing services to Gazprom Germania and/or any of its Subsidiaries

  5. payments and loan arrangements between Gazprom Germania and/or any of its Subsidiaries

  6. issuing and providing financing for letters of credit

All persons using the licence are required to keep accurate, complete and readable records, on paper or electronically, of any activity purporting to have been permitted under this licence for a minimum of 6 years. These documents must be made available on request by the Treasury.


The permissions in General Licence IOM/2022/RUS031 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 29 October 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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