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Financial Sanctions: Russia General Licence

Monday, 12 September 2022

General licence - IOM/2022/RUS030

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

On 23 August 2022, the Treasury issued General Licence IOM/2022/RUS030 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').

On 9 September 2022, General Licence IOM/2022/RUS030 was amended to update the meaning of a Bank. A Bank is a person or a firm with a Part 2, Chapter III permission of the Financial Services Act 2008 (of Tynwald) which includes the regulated activity of deposit taking, and which is a credit institution; but which is not a building society, a friendly society, a credit union or any other class of institution excluded by an order made by the Treasury.

Any persons intending to use General Licence IOM/2022/RUS030 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/RUS030 allows banks to take payment of bank fees from frozen accounts.  

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/RUS030 allows for the payments of bank fees and service charges. Under this licence:

  • A bank may take the payment of bank and service fees from accounts frozen under the Russia Regulations, arising from the routine holding or maintenance of those accounts. This includes taking payment for arrears of such fees. Payments to banks designated under the Russia Regulations are not permitted to take these payments

  • Persons incurring tax liabilities for making these payments can pay those tax liabilities to the Treasury


The permissions in General Licence IOM/2022/RUS030 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 is of indefinite duration.

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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