Introduction
1. The Syria (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 repressing the civilian population in Syria or who is or has been involved in supporting or benefitting from the Syrian regime and who are or have been carrying on activities related to chemical weapons.
2. On 29 June 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:
- Andrei Mikhailovich BOGATOV
- Alexander Yuryevich CHAIKO
- Sergey Fedorovich RUDSKOY
- Andrey Nikolaevich TROSHEV
- EVRO POLIS LLC
- MERCURY LLC
- VELADA LLC
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 Syria 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: SYRIA
ADDITIONS
Individuals
1. BOGATOV, Andrei Mikhailovich
Name (non-Latin script): Богатов, Андрей Михайлович
Title: Commander DOB: 14/06/1964. POB: Stary Oskol, Belgorod Region, Russia a.k.a: BOGATOV, Andrei, Mychailovych Nationality: Russia Position: Was Head of the 4th Reconnaissance and Attack Company of the Wagner Group Other information: (UK Sanctions List Ref): SYR0383 (UK Statement of Reasons): Andrei Mikhailovich Bogatov was the Head of the 4th Reconnaissance and Attack Company of the Wagner Group. As such he was a member of a militia which supported the Syrian regime and repressed the civilian population in Syria. (Gender): Male Listed on: 29/06/2022 UK Sanctions List Date Designated: 29/06/2022 Last Updated: 29/06/2022 UK Consolidated Group ID: 15431.
2. CHAIKO, Alexander Yuryevich
Name (non-Latin script): Александр Юрьевич Чайко
Title: Lieutenant General DOB: 27/07/1971. POB: Moscow Region, Russia a.k.a: CHAYKO, Alexander, Yuryevich Nationality: Russia Address: Russia. Position: Head of Armed Forces Group in Syria Other Information: (UK Sanctions List Ref): SYR0382 (UK Statement of Reasons): Alexander Yuryevich Chaiko was the Head of the Russian forces in Syria from September 2019 until at least September 2020. Through this role he has been involved in repressing the civilian population in Syria and supporting or benefiting from the Syrian regime. (Gender): Male Listed on: 29/06/2022 UK Sanctions List Date Designated: 29/06/2022 Last Updated: 29/06/2022 UK Consolidated Group ID: 15430.
3. RUDSKOY, Sergey Fedorovich
Name (non-Latin script): Сергей Федорович Рудской
Title: Colonel General DOB: 02/10/1960. POB: Ukraine a.k.a: RUDSKOI, Sergei, Fedorovich Nationality: Russia Address: Russia. Position: (1) Head of the Main Operations Directorate of the General Staff of the Armed Forces of the Russian Federation (2) First Deputy Chief of the General Staff of the Armed Forces of the Russian Federation (3) Colonel General Other Information: (UK Sanctions List Ref): SYR0385 (UK Statement of Reasons): Sergey Fedorovich Rudskoy is Head of the Main Operations Directorate of the General Staff of the Armed Forces of the Russian Federation - First Deputy Chief of the General Staff of the Armed Forces of the Russian Federation, Colonel General since 2015. In this role he has overseen the Russian forces in Syria. As such he has supported the regime and been involved in the violent repression of Syria’s civilian population. (Gender): Male Listed on: 29/06/2022 UK Sanctions List Date Designated: 29/06/2022 Last Updated: 29/06/2022 UK Consolidated Group ID: 15433.
4. TROSHEV, Andrey Nikolaevich
Name (non-Latin script): Трошев, Андрей Николаевич
Title: (1) Executive Director (2) Retired Colonel DOB: 05/04/1953. POB: Leningrad, Russia a.k.a: TROSHEV, Andrei, Mikolayvych Nationality: Russia Position: Commander, Wagner Group Other Information: (UK Sanctions List Ref): SYR0384 (UK Statement of Reasons): Andrey Nikolaevich Troshev was the Chief Executive of the Wagner Group. Therefore, he has supported the Syrian regime, was a member of a militia, and has repressed the civilian population in Syria. (Gender): Male Listed on: 29/06/2022 UK Sanctions List Date Designated: 29/06/2022 Last Updated: 29/06/2022 UK Consolidated Group ID: 15432.
ENTITIES
1. EVRO POLIS LLC
Address: Ulitsa Bratev Gozozaninykh Dom 2B, Pomeshchenie 3.1, Krasnogorsk, Russia, 143409. Other Information: (UK Sanctions List Ref): SYR0386 (UK Statement of Reasons): Evro Polis LLC operates in the oil and gas industry in Syria and is therefore involved in supporting or benefiting from the Syrian regime. The company is associated with Yevgeny Prigozhin who is a person who is or has been so involved. (Type of entity): Limited Liability Company (LLC) Listed on: 29/06/2022 UK Sanctions List Date Designated: 29/06/2022 Last Updated: 29/06/2022 UK Consolidated Group ID: 15434.
2. MERCURY LLC
Address: Leninsky Prospekt, Dom 137, Building, Local 2, Room 5, Moscow, Russia. Other Information: (UK Sanctions List Ref): SYR0387 (UK Statement of Reasons): Mercury LLC operates in the oil and gas industry in Syria and is therefore involved in supporting or benefiting from the Syrian regime. The company is associated with Yevgeny Prigozhin who is a person who is or has been so involved. (Type of entity): Limited Liability Company (LLC) Listed on: 29/06/2022 UK Sanctions List Date Designated: 29/06/2022 Last Updated: 29/06/2022 UK Consolidated Group ID: 15435.
3. VELADA LLC
Address: Ochakovskoye Shosse Dom 28, Building 2, Local 3, Room 8, Moscow, Russia. Other Information: (UK Sanctions List Ref): SYR0388 (UK Statement of Reasons): Velada LLC operates in the oil and gas industry in Syria and is therefore involved in supporting or benefiting from the Syrian regime. The company is associated with Yevgeny Prigozhin who is a person who is or has been so involved. (Type of entity): Limited Liability Company (LLC) Listed on: 29/06/2022 UK Sanctions List Date Designated: 29/06/2022 Last Updated: 29/06/2022 UK Consolidated Group ID: 15436.
Ministry of External Relations
29 June 2022