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Financial Sanctions: Russia General Licence RUS033

Thursday, 10 November 2022

General licence - IOM/2022/RUS033

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/RUS033 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”) and Regulation 32 of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019, as they extend to the Isle of Man by the Republic of Belarus (Sanctions) (EU Exit) (Isle of Man) Order 2021 [SI 2021/1257] (“the Belarus Regulations”).

Any persons intending to use General Licence IOM/2022/RUS033 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/RUS033 which, subject to certain conditions, allows payments to be made for legal professional fees and expenses associated with the provision of legal services.

For the purposes of General Licence IOM/2022/RUS033, a Designated Person (DP) means any individual or body of persons (corporate or unincorporate) designated by the Secretary of State under regulation 5 (as it has effect in the United Kingdom) of the Russia Regulations or the Belarus Regulations and/or any individual or body of persons (corporate or unincorporate) owned or controlled by that designated person as determined under the criteria set out in the Russia Regulations or the Belarus Regulations (in particular regulation 7 of and Schedule 1 to each of those Regulations).

Economic resources mean assets of every kind, whether tangible or intangible, movable or immovable, which are not funds but can be used to obtain funds, goods, or services as defined in section 60(2) of the Sanctions and Anti-Money Laundering Act 2018 (of Parliament).

Funds carries the same meaning as in section 60(1) of the Sanctions and Anti-Money Laundering Act 2018 (of Parliament) and means financial assets and benefits of every kind, including (but not limited to):

  • Cash, cheques, claims on money, drafts, money orders and other payment instruments

  • Deposits, balances on accounts, debts and debt obligations

  • Publicly and privately traded securities and debt instruments, including stocks and shares, certificates representing securities, bonds, notes, warrants, debentures and derivative products

  • Interest, dividends and other income on or value accruing from or generated by assets

  • Credit, rights of set-off, guarantees, performance bonds and other financial commitments

  • Letters of credit, bills of lading and bills of sale

  • Documents providing evidence of an interest in funds or financial resources

  • Any other instrument of export financing

A Person, as defined in section 9(5) of the Sanctions and Anti-Money Laundering Act 2018 (of Parliament) includes a body of persons corporate or unincorporate but does not include a DP.

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/RUS033 provided that one of the sets of conditions in one of parts A or B of the General Licence are complied with in full, any Person or Relevant Institution may receive payments from a DP; make payments (directly or indirectly) for or on behalf of a DP; make payments for the benefit of a DP; process payments which relate to a DP; and any Person or Relevant Institution may carry out any other act which is reasonably necessary to give effect to this.


The permissions in General Licence IOM/2022/RUS033 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, the Belarus Regulations, or any other regulations made under the Sanctions and Anti-Money Laundering Act 2018 (of Parliament) save as specifically permitted under this or other licences granted by the Treasury.

The General Licence takes effect from the date of issue and expires on 27 April 2023 and may be varied, revoked or suspended by the Treasury at any time.

Reporting requirement

Any activity conducted under General Licence IOM/2022/RUS033 must be reported to the Treasury within 7 days, with the details and supporting evidence requested in Part A or Part B. The reporting forms referenced at 9.4 of Part A and 11.4 of Part B of General Licence IOM/2022/RUS033 may be downloaded from the Sanctions and Export Control page under the accordion 'Sanctions Licences'.

Record-keeping requirements

A DP or Person must 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.

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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