Director disqualification designation
1. On 9 April 2025 the UK Government varied the designations of certain individuals and entities across UK autonomous and mixed sanctions regimes, meaning they are now subject to Director Disqualification Sanctions (‘DD sanctions’) under the UK regulations made under the Sanctions and Anti-Money Laundering Act 2018 (the ‘UK Regulations’). A link to the UK Sanctions List can be found below.
3. Following the introduction of DD sanctions measures in Jersey on 27 February 2025 it is an offence for a person subject to DD Sanctions to: - act as a director of a Jersey company, or
- directly or indirectly take part in or be concerned in the promotion, formation or management of a Jersey company
- act as a manager of a Jersey limited liability company, or
- directly or indirectly take part in or be concerned in the promotion, formation or management of a Jersey limited liability company
unless a licence or exception is in place.
4. Any changes to sanctions designations made under the UK Regulations are effective immediately by virtue of the ambulatory provisions in Jersey's sanctions legislation.
5. The entries to the UK sanctions list across the following UK autonomous and mixed sanctions regimes has been varied in respect of 2996 individuals and 818 entities to include designation for the purposes of DD sanctions.
- Belarus
- Bosnia and Herzegovina
- Central African Republic
- Chemical Weapons
- Counter-Terrorism (Domestic)
- Counter-Terrorism (International)
- Cyber
- Domestic People’s Republic of Korea
- Domestic Republic of Congo
- Global Anti-Corruption
- Global Human Rights
- Guinea-Bissau
- Guinea
- Iran (Nuclear)
- Iran
- Libya
- Mali
- Myanmar
- Nicaragua
- Russia
- South Sudan
- Sudan
- Syria
- Venezuela
- Yemen
- Zimbabwe
Jersey general licence (director disqualification)
6. The Sanctions Order does not provide for the automatic disqualification of acting directors who become subject to DD Sanctions.
7. 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').
8. 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).
9. 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.
10. 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.
Further information
11. Sanctions legislation update director disqualification sanctions
12. Jersey general licence (director disqualification)
13. Further guidance on sanctions and on the introduction of DD sanctions in Jersey can be found on the Government of Jersey and Jersey Financial Services Commission (JFSC) website.
14. Details of the UK sanctions regulations by regime are available at: Financial sanctions targets by regime.
15. Further information on sanctions can be found on the Government of Jersey and Jersey Financial Services Commission (JFSC) websites.
16. Jersey guidance on sanctions by regime is available at: JFSC Sanctions by country and category.
17. 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.
18. The UK Sanctions List on GOV.UK.
19. The UK Office of Financial Sanctions Implementation Consolidated List on GOV.UK.
Enquiries
20. Non-media enquiries, sanctions compliance reporting, and licence applications should be addressed to the Financial Sanctions Implementation Unit at sanctions@gov.je.
gov.je