Isle of Man Government - Financial Sanctions: Russia

This news release is issued to publicise the addition of 6 entries under the Russia sanctions regime.

The Russia (Sanctions) (EU Exit) Regulations 2019 have effect in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024 ('the Regulations'), which are made under the Sanctions Act 2024. This regime imposes financial, trade, aircraft, shipping and immigration sanctions for the purposes of encouraging Russia to cease actions which destabilise Ukraine, or undermine or threaten the territorial integrity, sovereignty or independence of Ukraine.

Individuals and entities who are designated under this regime are included on the UK sanctions list.

Types of sanctions applicable under this regime –

Asset freeze
Other financial and investment restrictions
Trade
Immigration
Aircraft
Ships

On 28 October 2024 the Foreign, Commonwealth and Development Office updated the UK sanctions list. This list provides details of those designated under sanctions legislation.

Additions

The following individuals have been added to the Consolidated List and are now subject to an asset freeze, trust services sanctions, travel ban and internet services sanctions:

Individuals

GAMBASHIDZE, Ilya Andreevich
Name (non-Latin script): Илья Андреевич Гамбашидзе
DOB: 07/05/1977. POB: Kyiv, Ukraine Nationality: Russia Passport Number: 756410352 National Identification Number: 771401746465 National Identification Details: Russia INN Address: 16 Zorge, Apt 57, Moscow, Russia. Position: Director of Structura and The Social Design Agency Other Information: (UK Sanctions List Ref): RUS2290. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 28/10/2024. (UK Statement of Reasons): Ilya Andreevich Gambashidze (hereafter Gambashidze) is an 'involved person' under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis of the following grounds: 1) Gambashidze is and has been obtaining a benefit from the Government of Russia by acting as a director or equivalent of entities, the Social Design Agency and Structura, which are carrying on business in a sector of strategic significance to the Government of Russia, namely the Russian information, communications and digital technologies sector; and 2) Gambashidze is and has been involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine, by working as a director or equivalent of entities, the Social Design Agency and Structura, that are responsible for, engage in, provide support for, or promote any policy or action which destabilises Ukraine or undermines or threatens the territorial integrity, sovereignty or independence of Ukraine. (Phone number): (1) +79165359238 (2) +79163900633 (3) +79166774005 (Email address): ilgamb7@gmail.com (Gender): Male Listed on: 28/10/2024 UK Sanctions List Date Designated: 28/10/2024 Last Updated: 28/10/2024 Group ID: 16614
PERLA, Andrey Naumovich
Name (non-Latin script): Андрей Наумович Перла
DOB: 31/12/1973. POB: Samara, Russia a.k.a: PERLA, Andrei, Naumovich Nationality: Russia Passport Number: 3604110270 National Identification Number: 631605846798 National Identification Details: Russia INN Address: (1) Gurzufskaya 16/102, Yekaterinburg, Russia. (2) Maslennikova 41/24, Samara, Russia. Position: The Programme Director of Social Design Agency Other Information: (UK Sanctions List Ref): RUS2289. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 28/10/2024. (UK Statement of Reasons): Andrey Naumovich Perla (hereafter Perla) is an 'involved person' under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis of the following grounds: 1) Perla is and has been obtaining a benefit from the Government of Russia by acting as a director or equivalent of an entity, Social Design Agency, which is carrying on business in a sector of strategic significance to the Government of Russia, namely the Russian information, communications and digital technologies sector; 2) Perla is and has been involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine, by working as a director or equivalent of an entity, Social Design Agency, that is responsible for, engages in, provides support for, or promotes any policy or action which destabilises Ukraine or undermines or threatens the territorial integrity, sovereignty or independence of Ukraine; and 3) Perla is and has been involved in destabilising Ukraine, undermining, or threatening the territorial integrity, sovereignty, or independence of Ukraine by promoting policies and actions which destabilise Ukraine, undermine and threaten the territorial integrity, sovereignty, and independence of Ukraine. (Phone number): (1) +79220206444 (2) +79193175340 (3) +79221630515 (4) +79220279500 (5) +79783000289 (Email address): (1) perla0606@mail.ru (2) dvp32@sev.gov.ru (3) andrewperla@gmail.com (Gender): Male Listed on: 28/10/2024 UK Sanctions List Date Designated: 28/10/2024 Last Updated: 28/10/2024 Group ID: 16613
TUPIKIN, Nikolai Aleksandrovich
Name (non-Latin script): Николай Александрович Тупикин
DOB: 06/06/1977. POB: Moscow, Russia a.k.a: TUPIKIN, Nikolay, Aleksandrovich Nationality: Russia Passport Number: 727760853 National Identification Number: 4503851519 Address: Raspletina, Dom 17, Korpus 2, Kv. 7, Moscow, Russia, 123060. Position: The General Director of Structura Other Information: (UK Sanctions List Ref): RUS2291. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 28/10/2024. (UK Statement of Reasons): Nikolai Aleksandrovich Tupikin (hereafter Tupikin ) is an 'involved person' under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis of the following grounds: 1) Tupikin is and has been obtaining a benefit from the Government of Russia by acting as a director or equivalent of an entity, Structura, which is carrying on business in a sector of strategic significance to the Government of Russia, namely the Russian information, communications and digital technologies sector; and 2) Tupikin is and has been involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine, by working as a director or equivalent of an entity, Structura, that is responsible for, engages in, provides support for, or promotes any policy or action which destabilises Ukraine or undermines or threatens the territorial integrity, sovereignty or independence of Ukraine. (Phone number): (1) +79104626802 (2) +74991967100 (3) +79160353451 (Email address): (1) natupikin@mail.ru (2) kurnikoff@yandex.ru (3) nikolay.tupikin@gmail.com (Gender): Male Listed on: 28/10/2024 UK Sanctions List Date Designated: 28/10/2024 Last Updated: 28/10/2024 Group ID: 16615

The following entities are now subject to an asset freeze, trust services sanctions and internet services sanctions:

Entities

ANO DIALOG
Name (non-Latin script): AHO ДИАЛОГ
a.k.a: AUTONOMOUS NON-PROFIT ORGANIZATION FOR THE DEVELOPMENT OF DIGITAL PROJECTS IN THE FIELD OF PUBLIC RELATIONS AND COMMUNICATIONS DIALOGUE (nonLatin script: АВТОНОМНАЯ НЕКОММЕРЧЕСКАЯ ОРГАНИЗАЦИЯ ПО РАЗВИТИЮ ЦИФРОВЫХ ПРОЕКТОВ В СФЕРЕ ОБЩЕСТВЕННЫХ СВЯЗЕЙ И КОММУНИКАЦИЙ ДИАЛОГ) Address: 11, Bldg. 1, FLOOR 1, ROOMS VI ROOM 14, TIMUR FRUNZE STREET, MUNICIPAL DISTRICT KHAMOVNIKI, Moscow, Russia, 119021. Other Information: (UK Sanctions List Ref): RUS2294. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 28/10/2024. (UK Statement of Reasons): ANO DIALOG is an involved entity under the Russia (Sanctions) (EU Exit) Regulations 2019 because it is or has been involved in: obtaining a benefit from or supporting the Government of Russia, through 1) carrying on business as a Government of Russia-affiliated entity, and; 2) carrying on business in a sector of strategic significance, namely, the Russian information, communications and digital technologies sector. (Business Reg No): 9709056472 - Russia INN Listed on: 28/10/2024 UK Sanctions List Date Designated: 28/10/2024 Last Updated: 28/10/2024 Group ID: 16618
SOCIAL DESIGN AGENCY
Name (non-Latin script): Агенство Социального Проектирования
a.k.a: (1) Agentstvo Sotsialnogo Proektirovaniya (2) SDA Address: (1) Per. Bolshoi Kislovskiy,  d. 1, str. 2,  Arbat Municipal Okrug, Moscow, Russia, 125009. (2) Prospekt Novoyasenevskii, d. 23, k. 1, Moscow, Russia, 117463. Other Information: (UK Sanctions List Ref): RUS2292. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 28/10/2024. (UK Statement of Reasons): The Social Design Agency (hereafter 'SDA') is an 'involved person' under the Russia (Sanctions) (EU Exit) Regulations 2019 on the basis of the following grounds: 1) The SDA is obtaining a benefit from or supporting the Government of Russia by carrying on business in a sector of strategic significance, namely the200 information, communications and digital technologies sector; and 2) the SDA is and has been involved in destabilising or undermining the territorial integrity, sovereignty or independence of Ukraine. Listed on: 28/10/2024 UK Sanctions List Date Designated: 28/10/2024 Last Updated: 28/10/2024 Group ID: 16616
STRUCTURA NATIONAL TECHNOLOGIES
Name (non-Latin script): Группа Компаний Структура a.k.a: (1) Company Group Struktura LLC (2) GK Struktura (non-Latin script: ГК Структура) (3) Gruppa Kompanii Struktura (non-Latin script: Группа Компаний 'Структура') (4) Structura (5) Structura National Technology (6) Struktura National Technologies Address: (1) Pereulok Bolshoi Kislovskiy, d. 1, str. 2, Arbat Municipal Okrug, Moscow, Russia, 125009. (2) Ulitsa Bolshaya Nikitskaya, d. 12, str. 1, Moscow, Russia, 125009. Other Information: (UK Sanctions List Ref): RUS2293. Financial sanctions imposed in addition to an asset freeze: Trust services. Date trust services sanctions imposed: 28/10/2024. (UK Statement of Reasons): Structura National Technologies (hereafter ‘Structura’) is an involved person under the Russia (EU Exit) (Sanctions) Regulations 2019 on the basis of the following grounds: (1) Structura is obtaining a benefit from or supporting the Government of Russia by carrying on business in a sector of strategic significance, namely the information, communications and digital technologies sector; and (2) Structura engages in, provides support for, or promotes any policy or action which destabilises Ukraine or undermines or threatens the territorial integrity, sovereignty or independence of Ukraine. Listed on: 28/10/2024 UK Sanctions List Date Designated: 28/10/2024 Last Updated: 28/10/2024 Group ID: 16617

What you must do

If you suspect a person or entity is a match to a person or entity included in the UK Sanctions List, and you hold or otherwise deal with funds or economic resources of that person:

You must freeze the assets immediately
You must review the information you hold for that person against the UK Sanctions List to ensure you do not have a false positive identification
Do not deal with those assets or make them available to, or for the benefit of the designated person unless:

You have a legal exemption
You have a licence

You must report the frozen assets to the FIU

If you have a suspicion or knowledge that there has been a breach of sanctions law, or any attempted transactions that you have blocked, report your suspicions to the FIU.

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

Where a relevant institution has already reported details of accounts, other funds or economic resources held frozen for the designated person, you are not required to report these details again.

Note: determining if a customer is on the UK Sanctions List includes whether any corporate entity is owned or controlled, directly or indirectly, by a person on the UK Sanctions List.

Further guidance on false positives and delistings and what to do can be found in the Financial Sanctions General Guidance page.

Further Information

Further information on the sanctions regime related to Russia and other sanctions related guidance can be found on the Sanctions and Export Control website on the Sanctions Guidance page.

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.