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Financial Sanctions: Russia General Licence

Tuesday, 21 March 2023

General licence - IOM/2023/RUS040

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

On 20 March 2023, the Treasury issued General Licence IOM/2023/RUS040 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”).

Any persons intending to use General Licence IOM/2023/RUS040 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/2023/RUS040 permits the wind down of Trust Services provided to Designated Persons otherwise prohibited by Regulation 18C of the Russia Regulations.  

Further to that, for a period of 120 days from the date the person to whom those Trust Services are being provided has been designated the General Licence allows:

  • any activity to be undertaken by a Person necessary to terminate an arrangement between them and a Designated Person for that Person to provide Trust Services including:
    • The continued provision of Trust Services being provided to a Designated Person on the date they were designated; and
    • Trust Services provided to a Designated Person after the date they were designated.

In addition, a Relevant Institution may conduct activities including processing payments made in accordance with those permissions.

The General Licence does not authorise activity prohibited by Regulations 11-15 of the Russia Regulations or to which the exception at Regulation 60ZZB (1) (b) applies.

For the purposes of General Licence IOM/2023/RUS040 Trust Services are services prohibited by regulation 18C of the Russia Regulations, consisting of:

  • The creation of a trust or similar arrangement;
  • The provision of a registered office, business address, correspondence address or administrative address for a trust or similar arrangement;
  • The operation or management of a trust or similar arrangement; or
  • Acting or arranging for another person to act as trustee of a trust or similar arrangement.

A Person is an individual, a body of persons corporate or unincorporated, any organisation or any association or combination of persons. A Designated Person is any individual or body of persons (corporate or unincorporate) designated by the Secretary of State under regulation 5 of the Russia Regulations (as it has effect in the United Kingdom) for the purposes of regulation 18C.

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)

The General Licence includes reporting and record keeping requirements. The Treasury have issued a reporting form to assist trust services providers in reporting information to the Treasury effectively. Reporting forms, and associated evidence, should be provided to the Treasury electronically at: and should be submitted within 30 days of undertaking an activity under this General Licence as set out below. Access the reporting form.

  • Details of the Designated Persons;
  • Details of any Participants to the Trust who are:
    • Owned or controlled by a Designated Person in accordance with regulation 7 of the Russia Regulations; or
    • Not owned or controlled by a Designated Person in accordance with regulation 7 of the Russia Regulations but provide Trust Services to or for the benefit of a Designated Person.
  • Value and type of any assets dealt with pursuant to the activity undertaken; and
  • Details of the activity undertaken pursuant to this licence, including but not limited to the Trust Services provided, and in respect of any payments made:
    • The date payment was made;
    • The amount of the payment;
    • The reason for the payment; and
    • The payment route used.


The permissions in General Licence IOM/2023/RUS040 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. It will expire in respect of each Designated Person with whom a Person has an arrangement with to provide Trust Services at 23.59 on the 120th day from 00:01 on the date that person is designated for the purposes of Regulation 18C.

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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