Introduction
1. The Russia (Sanctions) (EU Exit) Regulations 2019 (the “UK Regulations") were made under the Sanctions and Anti-Money Laundering Act 2018 and provide for the imposition of financial sanctions, including asset freezes and other financial and investment restrictions, on persons who are or have been involved in destabilising Ukraine or undermining or threatening the territorial integrity, sovereignty or independence of Ukraine; or obtaining a benefit from or supporting the Government of Russia.
2. On 28 October 2024 the Foreign, Commonwealth and Development Office updated the UK Sanctions List to reflect changes to those persons designated under the UK Regulations. A link to the UK Sanctions List can be found below.
3. The Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021, made under the Sanctions and Asset-Freezing (Jersey) Law 2019 (“SAFL"), links to the UK Regulations.
4. Any changes to asset-freeze designations made under the UK Regulations are effective immediately by virtue of the ambulatory provisions in Jersey's sanctions legislation.
5. An asset freeze now applies to the entries listed in the Annex to this Notice under Part 3 of SAFL.
Notice summary
6. Find full details in the Annex to this notice.
7. The following entries have been made and are now subject to an asset freeze and trust services sanctions:
Ilya Andreevich GAMBASHIDZE (UK Consolidated Group ID: 16614)
Andrey Naumovich PERLA (UK Consolidated Group ID: 16613)
Nikolai Aleksandrovich TUPIKIN (UK Consolidated Group ID: 16615)
ANO DIALOG (UK Consolidated Group ID: 16618)
SOCIAL DESIGN AGENCY (UK Consolidated Group ID: 16616)
STRUCTURA NATIONAL TECHNOLOGIES (UK Consolidated Group ID: 16617)
What you must do
8. You must:
immediately check whether you maintain any accounts or hold any funds or economic resources for the persons set out in the Annex to this Notice.
freeze such accounts, and other funds or economic resources without prior notice and without delay.
refrain from dealing with the funds or assets of making them available (directly or indirectly) to such persons unless licensed by the Minister for External Relations (“MER").
report any findings to MER, together with any additional information that would facilitate compliance with SAFL.
provide any information concerning the frozen assets of designated persons that MER may request. Information reported to MER may be passed on to other regulatory authorities or law enforcement.
9. Failure to comply with sanctions legislation or to seek to circumvent its provisions is a criminal offence.
Further information
10. Find guidance on unfreezing assets for delisted persons or entities.
11. Further information on sanctions can be found on Government of Jersey and Jersey Financial Services Commission (JFSC) websites.
12. Jersey guidance on the Russia sanctions regime is available at JFSC Sanctions by country and category.
13. A copy of the UK Regulations can be obtained from legislation.gov.uk. Other relevant information about this regime can be found on financial sanctions targets by regime on GOV.UK.
14. The UK Sanctions List on GOV.UK.
15. The UK Office of Financial Sanctions Implementation Consolidated List on GOV.UK.
Enquiries
16. Non-media enquiries, sanctions compliance reporting, and licence applications should be emailed to the Financial Sanctions Implementation Unit at sanctions@gov.je.
Annex
17. Annex to Financial Sanctions Notice Russia 28 October 2024