The Treasury advises that the Russia Sanctions (Application) (No.12) Regulations 2022 [SD 2022/0304] came into operation on 31 October 2022, which apply the provisions of the following United Kingdom statutory instrument relating to Russia financial and trade sanctions to the Island
- The Russia (Sanctions) (EU Exit) (Amendment) (No. 15) Regulations 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 were amended in the United Kingdom in response to Russian actions in Ukraine. The Isle of Man has adopted these measures to ensure that sanctions against Russia in the Island are aligned with the United Kingdom.
Further trade sanctions measures are imposed in relation to the export, making available, and supply or delivery of (and related technical assistance, financial services and funds, and brokering services):
- 'Russia’s vulnerable goods' (as specified in new Schedule 3I)
This is a wide-ranging and long list of goods that include wood products, chemicals, materials, machinery and electrical appliances. The goods on this list broadly fall into two categories: they are either:
- (a) critical intermediate goods that feed into supply chains for Russian industry, or
- (b) vulnerable intermediate or end use goods that are not humanitarian aid goods, basic food and food production goods, medical goods, basic personal or public communications technology, or domestic appliances
- (a) critical intermediate goods that feed into supply chains for Russian industry, or
- Energy-related goods and infrastructure-related goods – Additional G7 Dependancy and further Goods (as specified in new Part 3 of Schedule 3E)
This further aligns with the EU’s existing prohibitions to include oil refining technology and manufacturing products.
New trade prohibitions are imposed on the import, acquisition of goods that originate in or are consigned from Russia (as well as prohibitions on the provision of related technical assistance, financial services, funds, and brokering services):
- liquefied natural gas (as specified in new Chapter 4L of Part 5) (note these come into operation on 01 January 2023)
- gold and gold jewellery (as specified in new Chapter 4JA of Part 5)
- Russian spirits, liqueurs and other beverages (i.e. Russian vodka) and food waste products (primarily beet pulp) to align with EU measures (as specified in Schedule 3D)
The Regulations also expand on a ban that prohibits loans to certain companies connected with Russia or owned by person connected with Russia. It amends regulation 17(5) on loans and credit to bring companies outside Russia, but owned by a person connected with Russia into scope, including UK companies. In doing so it creates a new category of loan (category 5) and phases out the existing category of loan (category 3) to cover any loans made during the period between the original amendment regulations coming into operation and this amendment being made.
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.
