The Treasury has the power to issue General Licences for financial and trade sanctions regimes under a number of Regulations.
On 16 January 2026, the Treasury amended the above General Licence under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 ('the Regulations'), as they have effect in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024, which are made under the Sanctions Act 2024.
Any persons intending to use a General Licence should consult a copy of the Licence for full details of the permissions and usage requirements which can be found attached to this release.
General Licence – Russia – IOM/2024/RUS042 – Oil Price Cap permits the supply or delivery by ship of Russian crude oil and oil products, as well as provision of associated services, so long as the price paid for Russian oil or oil products is at or below the price cap. This general licence sets the price at USD $100 for 'premium to crude', and USD $45 for 'discount to crude'.
On 23 July 2025, General Licence IOM/2024/RUS042 was amended to reduce the crude oil price cap from $60.00 to $47.60 from 23:01 on 2 September 2025. Crude oil contracts signed at the previous cap of $60.00 before 23:01 on 2 September 2025 will be subject to a 45-day wind-down period; these contracts may be fulfilled provided that the oil is offloaded at the port of destination by 17 October 2025 at 23:01.
On 16 January 2026, General Licence IOM/2024/RUS042 was amended to reduce the crude oil price cap from $47.60 to $44.10 from 23:01 on 31 January 2026. Crude oil contracts signed at the previous cap of $47.60 before 23:01 on 31 January 2026 will be subject to a wind-down period; these contracts may be fulfilled provided that the oil is offloaded at the port of destination by 22:59 on 16 April 2026.
Subject to the exclusions and conditions and provided that no supply or delivery by ship of Russian oil or Relevant Services are provided to a Designated Person:
- A person may supply or deliver Russian oil by ship from a place in Russia to a third country or from one third country to another third country provided that the Unit Price of the Russian oil concerned is at or below the Price Cap
- A service provider may provide relevant services to any person provided that the unit price of the Russian oil being supplied or delivered by ship from a place in Russia to a third country or from one third country to another third country is at or below the Price Cap
- A Relevant Institution may process payments in relation to the activities authorised by paragraphs 1. and 2
The General Licence utilises an attestation process – on a per-voyage basis – which is designed to put different levels of requirement onto different actors in the oil supply chain, depending on whether they routinely know the price paid in their ordinary course of business and how often they transact. An attestation means a document:
- demonstrating that the Price Information of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap
- demonstrating that the Unit Price of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap
- attesting that the Unit Price of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap
- attesting that the Russian oil was purchased pursuant to a Licence issued under Part 4 of Schedule 5 of the Russia Regulations for example to enable anything to be done to deal with an extraordinary situation
- which, for Tier 3A and Tier 3B Providers, contains a clause within contractual terms and conditions that the Unit Price of the Russian oil to be supplied or delivered, or being supplied or delivered, is or will be at or below the Price Cap
Tier 1 Providers (and Tier 2 Providers with access to the information) are required to record itemised ancillary costs information – on a per-voyage basis – and provide them to other Tier 1, Tier 2 and Tier 3A contractual counterparties upon request.
Reporting and record-keeping requirements
The reporting and record-keeping requirements for a person supplying or delivering Russian oil or oil products are set out in the general licence.
Any persons intending to use the General Licence should consult the copy of the Licence for full details of the permissions and usage requirements.
General
The permissions in General Licences 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 Regulations, save as permitted under licences granted under the Regulations.
Further details of the sanctions regime related to Russia may be found on the Isle of Man Government website.
