The Treasury advises that there are amendments to the Sanctions (Implementation of UK Sanctions) Regulations 2024 [SD 2024/0118] (the ‘Regulations’) which gives legal effect in the Island, as Manx legislation, to United Kingdom Statutory Instruments concerned with United Nations and United Kingdom sanctions (‘UK sanctions provisions’).
On 14 November 2024 the UK government updated a number of UK sanctions provisions under the Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2024 (the ‘UK Amendment Regulations’).
The following changes will have affect in the Island, with modifications to the Regulations which is in line with the UK Amendment Regulations:
- Changing the existing requirements on relevant firms and involved persons to report suspected offences to a requirement to report suspected breaches of sanctions regulations
- An amendment to the notification requirements on the Treasury, when there is an issue, vary, suspend or revoke of a specific sanctions licence
- New civil monetary penalty powers for breaches in relation to Russia land prohibitions
- Moving existing DPRK land prohibitions to the Trade part of the DPRK regulations
- Updating the definition of designated person in Treasury licences schedules and exceptions provisions of sanctions regulations to confirm that this includes persons owned or controlled by named DPs
- An amendment to certain asset freeze prohibitions to explicitly apply to persons owned or controlled by named DPs
- An amendment to regulations 18C and 71 of the Russia regulations to clarify that acting as a nominee shareholder, when that involves the use of a trust or similar arrangement, should be considered a prohibited trust service
- An amendment to the ‘Disclosure to the Treasury’ provisions in most financial sanctions regulations to clarify the scope of the Treasury’s functions in connection with sanctions
- A modification to reporting requirements in relation to the assets of prohibited persons listed in regulation 18A of the Russia Regulations
- An expansion of the definition of relevant firms subject to financial sanctions reporting obligations to cover additional sectors – high value dealers, art market participants, insolvency practitioners and letting agencies
- Legislative changes to the licensing provisions in sanctions legislation. This includes an amendment to the pre-existing judicial decisions licensing purpose, the creation of a new insolvency licensing purpose. These changes do not apply in relation to UN regimes
The following changes are to be disregarded in the Island which are not in line with the UK Amendment Regulations:
- A requirement for all UK persons that hold funds or economic resources owned, held, or controlled by a designated person (DP), to provide an annual report to the Treasury with the details of these assets
- Licensing exception provision in sanctions legislation for a new required payments exception. This change does not apply in relation to UN regime
Further Information
Contact details for enquiries
If you require any further information or guidance, please contact the Sanctions Team on:
Telephone: +44 1624 648109
Email: sanctions@gov.im
Please note: We are unable to provide legal advice. You may need to seek independent legal advice. Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.
