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 freezing of funds and economic resources of certain persons, entities or bodies 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 14 April 2022 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 (the “Order”), 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 persons listed in the Annex to this Notice under Part 3 of SAFL.
Notice summary (Full details are provided in the Annex to this Notice)
6. The following designations have been made and are now subject to an asset freeze:
- Eugene TENENBAUM
- David DAVIDOVICH
What you must do
7. 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 notice and without delay.
- refrain from dealing with the funds or assets or making them available (directly or indirectly) to such persons unless licensed by the Minister for External Relations and Financial Services (“MERFS”).
- report any findings to MERFS, together with any additional information that would facilitate compliance with SAFL.
- provide any information concerning the frozen assets of designated persons that MERFS may request. Information reported to MERFS may be passed on to other regulatory authorities or law enforcement.
8. Failure to comply with sanctions legislation or to seek to circumvent its provisions is a criminal offence.
Further Information
9. Further information on sanctions can be found on the Government of Jersey website and the Jersey Financial Services Commission (JFSC) website.
10. Jersey guidance on the Russia sanctions regime is available on JFSC website.
11. Copies of Jersey sanctions legislation, including the Order and SAFL, can be found on the Jersey Legal Information Board website.
12. A copy of the UK Regulations can be obtained from legislation.gov.uk and other relevant information about this regime can be found on gov.uk.
13. A copy of the UK Sanctions List can be found here.
14. A copy of the UK Office of Financial Sanctions Implementation Consolidated List can be found here.
Enquiries
15. Non-media enquiries, sanctions compliance reporting, and licence applications should be addressed to:
Head of International Compliance
Office of the Chief Executive
External Relations
sanctions@gov.je
ANNEX TO NOTICE
FINANCIAL SANCTIONS: RUSSIA
ADDITIONS
Individuals
1. TENENBAUM, Eugene
DOB: --/09/1964. POB: Ukraine Nationality: Canada Other Information: (UK Sanctions List Ref):RUS1338 (UK Statement of Reasons):Eugene TENENBAUM is associated with Roman Abramovich. Roman Abramovich is an involved person under the Russia (Sanctions) (EU Exit) Regulation 2019. (Gender):Male Listed on: 14/04/2022 UK Sanctions List Date Designated: 14/04/2022 Last Updated: 14/04/2022 UK Consolidated Group ID: 15281.
2. DAVIDOVICH, David
DOB: 29/08/1962. POB: Russia Nationality: (1) Russia (2) Israel Other Information: (UK Sanctions List Ref):RUS1339 (UK Statement of Reasons):David DAVIDOVICH is a Russian/Israeli businessman closely associated with Roman ABRAMOVICH. ABRAMOVICH is an involved person under the Russia (Sanctions) (EU Exit) Regulation 2019. (Gender):Male Listed on: 14/04/2022 UK Sanctions List Date Designated: 14/04/2022 Last Updated: 14/04/2022 UK Consolidated Group ID: 15290.
Ministry of External Relations
14 April 2022