Sanctions Legislation: Russia

The Treasury advises that the Russia Sanctions (Application) (No. 3) Regulations 2023 [SD 2023/0339] comes into operation on 15 December 2023.

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 have been 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.

These Regulations amend the Russia (Sanctions) (EU Exit) Regulations 2019, as those Regulations have effect in the Island by applying to the Island (with modifications):

1. The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023
   
   and
   
   
2. The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023

The majority of amendments being made by the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 come into operation on 15^th December and include:

1. Extending the prohibition on Isle of Man credit or financial institutions from processing sterling payments to include any other currency to, from or via a designated person (directly or indirectly), subject to certain exceptions
   
   
2. Amending definitions of certain products such as goods and technology related to chemical or biological weapons, critical industry goods and technology, luxury goods, maritime goods and technology and oil refining goods and technology
   
   
3. Extending the prohibitions in relation to luxury goods, and consequentially amends relevant exceptions to the prohibitions
   
   
4. Inserting prohibitions in relation to the trade in certain metals, subject to certain exceptions
   
   
5. Adding a power for the Treasury to grant a licence for certain activities carried out by an Isle of Man entity in order to divest itself of assets, where those assets are subject to sanctions
   
   
6. The addition of new reporting obligations on relevant firms, and designated persons themselves (if they are an Island person), in relation to funds and economic resources that person owns or controls, the creation of penalties for breach of the obligations, and the power for the Treasury to impose civil monetary penalties for breach of the obligations.  These changes come into effect on 26 December 2023

The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023 come into operation on 1 January 2024 and create prohibitions on –

1. The import, acquisition and supply and delivery of diamonds and diamond jewellery which are located, originate in or are consigned from Russia
   
   and
   
   
2. The provision of ancillary services relating to the diamond prohibitions. Regulations 4 and 5 create certain exceptions to those prohibitions

The Russia Sanctions (Application) Regulations 2020 are also updated to include references to new Schedules to the 2019 Regulations which have effect in the Island from time to time.

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.

Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.