The Treasury has the power to issue General Licences for financial and trade sanctions regimes under a number of Regulations.
On 9 January 2026, the Treasury issued General Licence IOM/2026/RUS050 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.
General Licence IOM/2026/RUS050 allows, subject to certain conditions, transactions related to agricultural commodities including the provision of insurance and other services.
Any persons intending to use General Licence IOM/2026/RUS050 should consult the copy of the Licence for full details of the permissions and usage requirements which can be found attached to this release.
A DP means any individual or body of persons (corporate or unincorporate) designated for the purpose of section 9(2) of the Sanctions and Anti-Money Laundering Act 2018 (of Parliament) and/or any individual or body of persons (corporate or unincorporate) owned or controlled directly or indirectly by that designated person as determined under the criteria set out in the Regulation 7 and Schedule 1 of the Regulations (as they have effect in the United Kingdom).
A Person means an individual, a body of persons corporate or unincorporate, any organisation or any association or combination of persons which is not itself a DP.
A Relevant Institution has the meaning given in:
- a) Paragraph 2(1) of Schedule 2 of the Sanctions (Implementation of UK Sanctions) Regulations 2024 [SD 2024/0118] and
- b) Regulation 58(7) and (8) of the Regulations (as they have effect in the United Kingdom)
Banking Fees mean Service fees charged by a Relevant Institution, including transaction fees, payment fees or transfer fees.
Funds mean financial assets and benefits of every kind, including (but not limited to):
- Cash, cheques, claims on money, drafts, money orders and other payment instruments
- Deposits, balances on accounts, debts and debt obligations
- Publicly and privately traded securities and debt instruments, including stocks and shares, certificates representing securities, bonds, notes, warrants, debentures and derivative products
- Interest, dividends and other income on or value accruing from or generated by assets
- Credit, rights of set-off, guarantees, performance bonds and other financial commitments
- Letters of credit, bills of lading and bills of sale
- Documents providing evidence of an interest in funds or financial resources
- Any other instrument of export financing
Economic resources mean assets of every kind, whether tangible or intangible, movable or immovable, which are not funds but can be used to obtain funds, goods or services, including Agricultural Commodities.
Dealing with means:
In relation to Funds, if a Person:
- Uses, alters, moves, transfers or allows access to the funds
- Deals with the funds in any other way that would result in any change in volume, amount, location, ownership, possession, character or destination or
- Makes any other change, including portfolio management, that would enable use of the funds
In relation to Economic Resources, if a Person:
- Exchanges the economic resources for funds, goods or services, or
- Uses the economic resources in exchange for funds, goods or services (whether by pledging them as security or otherwise)
An Insurance Provider means a firm with permission to effect or carry out contracts of insurance or reinsurance in the Isle of Man and registered by the Isle of Man Financial Services Authority (FSA), including a Designated Person if applicable.
A Trade Licence Holder means a Person, who is not a Designated Person, to whom a trade licence has been issued by the Treasury under regulation 65 of the Regulations or a Person who has notified the Treasury to use a General Licence under regulation 65 of the Regulations.
A Relevant Island National means a British citizen who is resident in the Isle of Man who is not a Designated Person, and who is employed by a non-Isle of Man incorporated Person outside of the Isle of Man, where such non-Isle of Man incorporated Person is neither a Designated Person nor a ‘person connected with Russia’ (nor owned, held or controlled by a Designated Person or a ‘person connected with Russia’). For the purposes of this Licence, a ‘person connected to Russia’ has the meaning given to it in regulation 19A(2) of the Regulations.
A Relevant Exporter means an exporter, producer, seller or transporter of Agricultural Commodities, who is not a Designated Person.
An Island Corporate means an Island-incorporated Person Person under the law of the Isle of Man as defined under Island Person in paragraph 2(2) of Schedule 2 of the Sanctions (Implementation of UK Sanctions) Regulations 2024 [SD 2024/0118] who is not a Designated Person or a Relevant Institution.
Agricultural Commodities means:
- Food
- Fertiliser
- Seed
- Feed and
- Reproductive materials (such as live animals, fertilized eggs, embryos, and semen) for the production of food for animals
Fertiliser means:
- Ammonium nitrate, including fertilisers and fertiliser blends containing more than 15% by weight ammonium nitrate, except liquid fertilisers (containing any amount of ammonium nitrate) or dry fertilisers containing less than 15% by weight ammonium nitrate, controlled under entry 1C997, as listed in Part 1A of Schedule 2A of the Russia Regulations (Critical-industry goods and critical-industry technology) and
- Ammonia in aqueous solution controlled under commodity code 2814 20 as listed in Schedule 3E Part 2 of the Russia Regulations (G7 dependency and further goods list goods)
Feed means any substance or product, including additives, whether processed, partially processed or unprocessed, intended to be used for oral feeding to animals; and Food means any substance or product, whether processed, partially processed or unprocessed, intended to be, or reasonably expected to be ingested by humans.
‘Food’ includes drink, chewing gum and any substance, including water, intentionally incorporated into the food during its manufacture, preparation or treatment. It includes water after the point of compliance as defined in Article 6 of Directive 98/83/EC and without prejudice to the requirements of Directives 80/778/EEC and 98/83/EC.
‘Food’ shall not include:
- Fodder or feeding stuffs for animals, birds or fish
- Live animals unless they are prepared for placing on the market for human consumption
- Plants prior to harvesting
- Medicinal products within the meaning of Council Directives 65/65/EEC(1) and 92/73/EEC(2)
- Cosmetics within the meaning of Council Directive 76/768/EEC(3)
- Tobacco and tobacco products within the meaning of Council Directive 89/622/EEC(4)
- Narcotic or psychotropic substances within the meaning of the United Nations Single Convention on Narcotic Drugs, 1961, and the United Nations Convention on Psychotropic Substances, 1971
- Residues and contaminants
Seed means those seeds listed at Schedule 1 of the Seed Marketing Regulations 2016
Financial Services means Financial Services as defined in section 3 of the Financial Services Act 2008.
GAFTA means The Grain and Feed Trade Association (registered in England & Wales with liability limited by guarantee under company number 01006456 and with a registered office at 9 Lincoln's Inn Fields, London, WC2A 3BP), an international trade association representing organisations, amongst other things, trading globally in Agricultural Commodities.
Under this licence Relevant Exporters or Trade Licence Holders may continue:
- Receiving Funds and Economic Resources from any Person, including from Designated Persons, in connection with the export, sale, production and transport of Agricultural Commodities or
- Transferring Funds or Economic Resources as follows:
- i. To Relevant Institutions, Insurance Providers or Relevant Island Nationals in connection with the export, sale, production and transport of Agricultural Commodities, including for the purchase of insurance and reinsurance
- ii. To Island Corporates in connection with the export, sale, production and transport of Agricultural Commodities
- iii. To Designated Persons in connection with the export, sale, production and transport of Agricultural Commodities and
- iv. To any other Person in connection with the export, sale, production and transport of Agricultural Commodities
- i. To Relevant Institutions, Insurance Providers or Relevant Island Nationals in connection with the export, sale, production and transport of Agricultural Commodities, including for the purchase of insurance and reinsurance
Under this licence Relevant Institutions, Insurance Providers, Island Corporates or Relevant Island Nationals may continue:
- Making Funds or Economic Resources available to, or for the benefit of, a Relevant Exporter, Trade Licence Holder or Designated Person in connection with a transaction relating to Agricultural Commodities
- Dealing with Funds or Economic Resources in connection with a transaction relating to Agricultural Commodities for/on behalf of a Relevant Exporter, Trade Licence Holder or Designated Person, including processing such Funds
- Providing insurance, reinsurance and underwriting services and any other Financial Service to a Relevant Exporter, Trade Licence Holder or Designated Person in connection with a transaction relating to Agricultural Commodities and
- Receiving Funds or Economic Resources from a Relevant Exporter or Trade Licence Holder in connection with a transaction relating to Agricultural Commodities, or from a Designated Person in accordance with the below paragraph
Under this licence Designated Persons may continue:
- Transferring Funds to Relevant Institutions or Insurance Providers to:
- i. Pay for insurance and reinsurance services in connection with a transaction relating to Agricultural Commodities
- ii. Pay Banking Fees in connection with a transaction relating to Agricultural Commodities and
- iii. Effect and/or process the transactions referred to in sub paragraphs 2 and 3 below
- i. Pay for insurance and reinsurance services in connection with a transaction relating to Agricultural Commodities
- Transferring Funds or Economic Resources to Relevant Exporters, Trade Licence Holders or Island Corporates in connection with the export, sale or production of Agricultural Commodities and
- Receiving Funds or Economic Resources from Relevant Exporters, Trade Licence Holders, Island Corporates, Relevant Institutions or Insurance Providers in connection with the export, sale or production of Agricultural Commodities
Any Relevant Institution may carry out any activity necessary to effect the permissions listed in this licence.
Under this licence GAFTA may continue:
- To receive Funds and Economic Resources from any Person, including from Designated Persons, in connection with the direct and indirect provision of services related to contracts for the trade in Agricultural Commodities, by or on behalf of GAFTA
- Allow Insurance Providers to provide professional indemnity insurance services to GAFTA in connection with direct and indirect services related to Agriculture Commodities
- Allow any Relevant Institution which holds accounts in GAFTA’s name to carry out any activity necessary to effect the permission listed in paragraphs 8 and 9 and
- Make clear that notification requirements do not apply to the GAFTA provisions in paragraphs 8 to 10
Notification and record-keeping requirements
The notification and record-keeping requirements for the DP, Persons, Relevant Institutions 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.
Notification provided above does not constitute verification by the Treasury that activity purporting to be permitted under this licence is permitted.
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, or any other regulations given effect in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024 [SD 2024/0118] save as specifically permitted under this or other licences granted by the Treasury.
Further details of the sanctions regime related to Russia may be found on the Isle of Man Government website.

