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Sanctions legislation update: director disqualification sanctions

Published byExternal Relations
TypeSanctions
Date published
27 February 2025

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Jersey general licence (director disqualification)

1. The Sanctions and Asset-Freezing (Implementation of External Sanctions – Director Disqualification) (Jersey) Amendment Order 2025 came into force today, 27 February 2025, amending the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (the 'Order'). Further information on the Order, as amended, can be found on the Jersey Gazette notice published on 20 February 2025 and on the Gov.je website.

2. On 27 February 2025 the Minister for External Relations (the 'Minister') issued the Jersey General Licence (Director Disqualification) INT/JSY/2025/1 (the 'Jersey General Licence').

3. The Jersey General Licence authorises:

  • acting company directors or the managers of limited liability companies who are designated for the purposes of DD Sanctions to undertake activities that are required in connection with the discharge of, or compliance with, Jersey or UK statutory or regulatory requirements; and

  • actions taken strictly in connection with the resignation of a disqualified person as a director of a company (as defined in Article 5A of the Order) or as a manager of a limited liability company (as defined in Article 5A of the Order).

4. The Jersey General Licence permits activity which would otherwise be prohibited by sanctions legislation. It does not obviate the need to comply with all other statutory, regulatory and fiduciary obligations.

5. The Jersey General Licence came into force on 27 February 2025 and expires on 31 December 2025.

6. Those who rely on the Jersey General Licence must report to the Minister within 7 working days of having done so, with details of any transactions or actions undertaken. Reports should be submitted to the Minister at sanctions@gov.je.

7. It is the responsibility of any party relying on the Jersey General Licence to ensure the activities they undertake fall within its terms and that they comply with all of its conditions. A person commits an offence and is liable to imprisonment for a term of 2 years and to a fine, if the person purports to act under the authority of the Jersey General Licence but fails to comply with any of its conditions.

8. A specific licence is required to undertake activity which falls outside the permissions granted under the Jersey General Licence. Licence applications should be made to the Minister at sanctions@gov.je using the sanctions licence application form provided.

​Designations under the new measure

9. No designations in respect of DD Sanctions have yet been made under any UK sanctions regimes. Any future designations will apply automatically and immediately in Jersey and an update will be published on the Jersey Gazette.

Further information

10. The UK Sanctions List on GOV.UK provides an up-to-date list of which people, entities and ships are designated or specified under UK sanctions regulations made under the UK Sanctions and Anti-Money Laundering Act 2018, and why.

11. Details of the UK sanctions regulations by regime are available at: Financial sanctions targets by regime​.

12. Further information on sanctions can be found on the Government of Jersey and Jersey Financial Services Commission (JFSC) websites.

13. Jersey guidance on sanctions by regime is available at: JFSC Sanctions by country and category.

Enquiries

14. Non-media enquiries, sanctions compliance reporting, and licence applications should be addressed to the Financial Sanctions Implementation Unit at sanctions@gov.je.

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Sanctions legislation update: director disqualification sanctions
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