Introduction
1. The Russia (Sanctions) (EU Exit) Regulations 2019 (the “UK Russia Regulations"), are implemented in Jersey under the Sanctions and Asset-Freezing (Jersey) Law 2019 (“SAFL") and the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021.
Reporting Obligation
2. In accordance with regulation 70(1ZA) of the UK Russia Regulations, a Relevant Financial Institution, as defined in article 1 of SAFL, must inform the Minister for External Relations (the “Minister") as soon as practicable if:
it knows, or has reasonable cause to suspect, that it holds funds or economic resources for a prohibited person; and
the information or other matter on which the knowledge or cause for suspicion is based came to it in the course of carrying on its business.
3. Prohibited persons are:
a) the Central Bank of the Russian Federation,
b) the National Wealth Fund of the Russian Federation,
c) the Ministry of Finance of the Russian Federation,
d) a person owned or controlled directly or indirectly by a person mentioned in sub-paragraphs (a) to (c), or
e) person acting on behalf of or at the direction of a person mentioned in sub-paragraphs (a) to (c).
4. For more detail, please see the Gazette notice issued earlier this year.
Annual Reporting Requirement
5. Additionally, in accordance with regulation 70(1ZB) of the UK Russia Regulations, where the Relevant Financial Institution knows, or has reasonable cause to suspect, that it holds funds or economic resources for a prohibited person, it must by no later than 31st October in each calendar year, provide a report to the Minister as to the nature and amount or quantity of those funds or economic resources held by that Relevant Financial Institution as of 30th September in that calendar year.
6. To comply with this requirement any Relevant Financial Institution holding such funds or resources must send a completed version of the Immobilised Assets Reporting Form, including any associated documents, to the Minister at sanctions@gov.je.
Further Information
7. Further information on sanctions can be found on Government of Jersey and Jersey Financial Services Commission (JFSC) websites.
8. Jersey guidance on the Russia sanctions regime is available at JFSC Sanctions by country and category.
9. 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.
10. The UK Sanctions List on GOV.UK.
11. The UK Office of Financial Sanctions Implementation Consolidated List on GOV.UK.
Enquiries
12. Non-media enquiries, sanctions compliance reporting, and licence applications should be emailed to the Financial Sanctions Implementation Unit at sanctions@gov.je.