Sanctions licences and exceptions

​​​​ Sanctions licences and exceptions in Jersey

Specific exceptions and licensing powers can allow otherwise prohibited transactions and prohibited activity t​o take place in some circumstances.

A licence is a written permission from the Minister for External Relations (the ‘Minister’) allowing an act that would otherwise breach prohibitions imposed by sanctions.

Grounds for licence applications are set out at Article 16 of the Sanctions and Asset-Freezing (Jersey) Law 2019​ (SAFL) and in the relevant UK Sanctions Regulations. For example, the Russia (Sanctions) (EU Exit) Regulations 2019 (the ‘UK Russia Regulations’) implemented in Jersey under the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (the ‘Sanctions Order’).

An exception to a prohibition applies automatically in certain defined circumstances as set out in:

• Article 15 of SAFL
• UK Sanctions Regulations implemented in Jersey under the Sanctions Order

An exception does not require you to obtain a licence from the Minister, although there may be reporting obligations.  

However, you should be particularly cautious when seeking to use exceptions in implemented UK Sanctions Regulations. Many such exceptions are drafted for a specific UK-context, for example referring to UK legislation.

The Financial Sanctions Implementation Unit (FSIU) cannot provide advice on an individual case or specific action. Applicants should consider taking independent legal advice before making any application or placing reliance on any exception, especially for complicated matters.

UK guidance on exceptions and licencing on GOV.UK

The UK guidance is specifically drafted for the UK sanctions regime. Whilst relevant to Jersey, it is important to consider this in the context of Jersey’s sanctions legislation and regime.

UK guidance, and the UK Regulations, should also be considered alongside the provisions and modifications of Schedule 2 of the Sanctions Order. For example, when UK guidance refers to ‘The Secretary of State’ this should be read as the ‘Minister for External Relations’. Any reference to the UK or a part of the UK should be read as a reference to Jersey.

The following guidance provides a general overview of the standard exceptions and licensing grounds found in financial sanctions legislation. The grounds may vary from regime to regime, so it is important that you check the relevant, up-to-date legislation.

Exceptions to prohibitions

Exceptions to prohibitions apply automatically in certain defined circumstances as set out in Article 15 of SAFL, and in UK Sanctions Regulations implemented in Jersey under the Sanctions Order. They do not require you to obtain a licence from the Minister. Examples of exceptions include:

Crediting frozen accounts 

Asset freezing legislation permits the following actions by a relevant financial institution, as defined in Article 1 of SAFL, without a licence so long as those funds are frozen immediately:

• crediting a frozen account with interest or other earnings due on the frozen account
• crediting a frozen account with payments due under contracts, agreements or obligations that were concluded or arose before the account became a frozen account
• crediting a frozen account where it received funds transferred to the account​

If a relevant financial institution credits a frozen account as described above, it must inform the Minister, as soon as practicable. In any case it must be within 14 days.

Independent person holding legal or equitable interest in frozen funds or economic resources

UK Sanctions Regulations create an exception to allow independent persons to transfer their legal or equitable interests in frozen funds or economic resources to another person, where immediately before the transfer all the provisions below are present:

• the independent person is not a designated person
  
• the independent person holds the interest in the funds or economic resources
  
• the independent person does not hold the interest jointly with a designated person
  
• the independent person isn’t owned or controlled, directly or indirectly, by a designated person
  

Permitted payments

From 5 December 2024, for non-UN designated persons only, it is permitted without a licence for various payments to be made from or on behalf of designated persons to certain UK public bodies. 

In Jersey this exception applies to payments to the equivalent bodies:

• the Jersey Financial Services Commission
• Revenue Jersey
• Jersey parishes

Where a required payment is made by a person other than a designated person, the designated person is permitted to make a reimbursement payment to that person.

Persons who use the exception to make a payment that would otherwise be prohibited under Jersey sanctions legislation must report to the Minister under the terms of the exception. Reporting should be submitted to sanctions@gov.je.

Licensing overview

A licence is a written permission from the Minister allowing an act that would otherwise breach prohibitions imposed by sanctions. It does not compel any party, including the financial institutions involved in the payment route, to take any action. It confirms, solely, that the acts specified in the licence are allowed by the Minister.

The Minister’s powers to grant licences are set out in Article 16 of SAFL and in Article 5 of the Sanctions Order. 

Licences cannot be issued retrospectively. If you have carried out an act that required a licence, without having obtained one beforehand, you may have breached sanctions. You should inform the Minister immediately at sanctions@gov.je.

The Minister only issues licences in relation to his areas of competence. A licence does not confirm that a particular transaction as a whole is lawful under financial sanctions regulations, for example, in some cases a further licence, such as an export control licence, may be required, or any other legislation.

The UK publishes the following guidance which provides additional information on sanctions licencing and exceptions under the UK regulations. It is specifically drafted for the UK context. Whilst much of the guidance provided may be relevant to Jersey, it is important to consider this in the context of Jersey’s sanctions legislation and regime. If you’re unsure about your obligations in a given case, you should consider taking independent legal advice.

UK financial sanctions general guidance on GOV.UK

UK financial sanctions guidance on GOV.UK​

Licencing grounds

The available grounds for a licence to be issued under Article 16 of SAFL (asset-freezing provisions) can be found in the Treasury Licences schedule of the relevant UK Sanctions Regulations.

The following grounds are commonly found in UK Sanctions Regulations:

Basic needs

UK Sanctions Regulations confirm that the ground is present to enable the basic needs of a designated person or, in the case of an individual, any financially dependent family member of such a person, to be met.

Expenditure to meet basic needs of an individual should be expenses which are necessary to ensure that designated persons or financially dependent family members are not imperilled.

In respect of a person other than an individual, for example an entity, the legislation confirms that basic needs includes:

• payment of insurance premiums
• payment of reasonable fees for the provision of property management services 
• payment of remuneration, allowances or pensions of employees 
• payment of tax  
• rent or mortgage payments
• utility charges 

The list of basic needs detailed above is not exhaustive but is indicative of the type of basic needs intended to be caught. Therefore, expenditure to meet the basic needs of an entity should be expenses strictly necessary to ensure the continued existence of the designated entity.

Basic needs licences do not necessarily enable a designated person to continue the lifestyle or business activities they had before they were designated.

Fees for the provision of legal services

Both legal fees and disbursements must be reasonable. It is for the applicant to demonstrate to the FSIU that the legal fees and disbursements are reasonable.

In most cases, you can provide legal advice to or act for a designated person without a licence from the Minister. However, you cannot receive any payment for that advice without first obtaining a licence from the Minister.

The Minister can only authorise payment of reasonable legal fees and disbursements in relation to legal services provided to a designated person. You are strongly encouraged to apply for a licence in advance of providing substantive legal services in order for you to have certainty as to the fees that will be recoverable whilst the designated person remains listed.

In support of your application, you should:

• provide an estimate of the anticipated fees and fees that have already been incurred
• provide a breakdown of how the fees will be charged or have been charge
• identify any disbursements, such as payments for counsel or expert witnesses

The FSIU considers that the UK’s Supreme Court Cost Guides or the sums that could be expected to be recouped if costs were awarded, provide a useful starting point for assessing the reasonableness of legal fees and disbursements.

If you are seeking fees of a level in excess of those, you need to demonstrate why those increased fees are reasonable in the given case.

Fees and disbursements must relate specifically to the provision of legal advice, involvement in litigation or in dispute resolution.

‘Legal Services’ means legal services provided to a DP, including legal advice and representation in court, whether provided within the UK or another jurisdiction, in relation to any matter except a claim for defamation or malicious falsehood.

Routine maintenance of frozen funds and economic resources

The fees or service charges must be reasonable and result in the routine holding or maintenance of frozen funds or economic resources.

The re-design, refurbishment or redevelopment in order to improve the value of a frozen economic resource is generally not covered. Although each application will be considered on a case-by-case basis.

Extraordinary expenses

This must be extraordinary in nature. Including, but not limited to, being:

• unexpected
• unavoidable
• non-recurring

It cannot be used where other licensing grounds are more suitable or as a way of avoiding the clear limitations of those other grounds.

Judicial decisions

For UN designated persons

This enables the use of frozen funds or economic resources subject of a judicial decision or lien which was established before the date of designation and enforceable in Jersey. The use of the funds or economic resources must be to implement or satisfy in whole or in part the pre-existing judicial decision or lien. It cannot be for the direct or indirect benefit of a designated person.

For non-UN designated persons only

This enables payments to implement or satisfy, in whole or in part, a judicial decision or lien that is enforceable in Jersey.

That decision or lien can have been made pre or post the date of a designation.

A designated person may make a payment to another designated person under this derogation. However, if funds or economic resources are made available to a designated person under this derogation they must be frozen in a Jersey or UK bank account or otherwise subject to the relevant asset freeze provisions and no other designated person can benefit from that.

Humanitarian assistance activity

This enables payments to facilitate:

• any humanitarian activity
• where applicable, any activity where its purposes are consistent with the objectives of UN Security Council Resolutions, which will be set out in the applicable UK Sanctions Regulations
  

Humanitarian assistance includes the work of international and non-governmental organisations carrying out relief activities for the benefit of the applicable civilian population, which may include the delivery of humanitarian aid or peace-building programmes.

A licence may still be required even if this activity is using government funds.

Diplomatic missions​

This enables anything to be done in order that the proper functions of a diplomatic mission or consular post or an international organisation enjoying immunities in accordance with international law, may be carried out.

Extraordinary situa​tions

This must be extraordinary in nature. Including, but not limited to, being:

• unexpected
• unavoidable
• non-recurring

This applies to non-UN designated persons and enables anything to be done to deal with an extraordinary situation. This will enable a licence to be issued to deal with a situation which is extraordinary in nature but does not necessarily involve an expense.

There is a high threshold for a situation to meet the standard of being extraordinary, and even where a situation may seem extraordinary to the parties concerned, for example outside their normal day to day business, it does not necessarily mean it will meet the threshold for this licensing ground. It cannot be used where other grounds are more suitable or as a way of avoiding the clear limitations of other licencing grounds or purposes.

Prior obligations

The obligation must have arisen prior to the date of designation and cannot relate to trade provisions as specified in the UK Sanctions Regulations. In addition, it cannot result in funds or economic resources being made directly or indirectly available to the designated person.

Divestment

The licensing grounds give the FSIU the authority to issue licences to enable UK or Jersey entities as set out below.

Full divestment

Wholly (fully) divest funds and economic resources they own, hold or control located within Russia or enable the facilitation of another person (Jersey or non-Jersey, including UK) to fully divest funds and economic resources owned, held or controlled by that person located within Russia.

Full divestment for the purposes of licensing requests under these grounds constitutes the transfer by a person or UK/Jersey entity (‘A’) of funds or economic resources located in Russia (the ‘Relevant Asset’), to either a DP or the Russian government, resulting in A having no remaining interests in the Relevant Asset.

It does not mean that A is required to transfer all of the funds or economic resources they own, hold or control in Russia, but they do need to divest their entire interest in the Relevant Asset.

The FSIU will not treat activity it considers to be business-as-usual as full divestment. This may include, but is not limited to activity:

• which restructures A’s ownership of the Relevant Asset so that A still owns or controls it via a different entity which A owns or control
• the object of which is to fulfil A’s contractual obligations, but which is not aimed at the full divestment of the Relevant Asset

Partial divestment

Partially divest funds and economic resources they own, hold or control located within Russia and/or enable the facilitation of another person (Jersey or non-Jersey (including UK)) to partially divest funds and economic resources that person owns, holds or controls located within Russia.

Partial divestment for the purposes of licensing requests under these grounds is a situation where a person or UK/Jersey entity (‘A’) has a decided to divest itself of particular funds and/or economic resources located in Russia (the ‘Relevant Asset’) as opposed to all of its funds and/or economic resources located in Russia to either a DP or the Russian government but wishes to only divest itself of a proportion of the Relevant Asset instead of all of it.

The applicant must provide evidence to demonstrate that this is part of a strategy to ultimately fully divest the Relevant Asset being partially divested, or a sufficient explanation as to why that is not possible.

The FSIU will not treat activity it considers to be business-as-usual as partial divestment. This may include, but is not limited to activity:

• that restructures A’s ownership of the Relevant Asset being partially divested so that A still owns or controls it via a different entity which A owns or controls
• the object of which is to fulfil A’s contractual obligations, but which is not aimed at the partial divestment of the Relevant Asset

In cases of both full and partial divestment, the FSIU will be very unlikely to license any activity where there is evidence that there is a potential for assets to be used in support of Russia’s war effort.

Divestment of investors who are designated persons

Divest investors who are designated under the Russia Regulations (‘DP’) or the Russian government or enable the facilitation of another person (Jersey or non-Jersey (including UK)) to divest themselves of investors who are DPs or the Russian government.

This divestment is only licensable where both of the following conditions are met: 

• the sole consideration for the divestment is a transfer of funds to a DP or the Russian government; and 
• those funds are transferred to a frozen account at a relevant financial institution, or an account held by a non-UK or non-Jersey credit or financial institution in a jurisdiction outside Jersey or the UK, the law of which provides for equivalent prohibitions, exceptions and licensing grounds. 

Insolvency

This licensing ground permits the Minister to license various payments and other activity in relation to insolvency, restructuring and related proceedings, provided that any payments made directly or indirectly to a designated person are credited to a frozen Jersey bank account. For the insolvency and restructuring proceedings specifically, these must also relate to an insolvent person.

As noted above, the exact grounds available can be found in the legislation underpinning each particular sanctions regime. Some licensing grounds cannot be applied to persons designated by the UN. The FSIU carefully scrutinises all applications made to assess whether they fall under the relevant licensing grounds. 

Non asset-freeze licence applications, made under Article 5 of the Sanctions Order, such as those in respect of prohibitions on trade, transport or shipping, must demonstrate that the relevant UK Regulations permit such a licence to be issued. Applicants should be able to demonstrate that the issuance of a licence would not serve to frustrate the purpose of the relevant provision in the UK Regulations. For example, if applying for a trade services licence you should show how providing your services would be consistent with the purposes of the sanctions.

Find guidance published by the UK Department for Business and Trade on how to apply for a licence to provide sanctioned trade services on GOV.UK. Whilst this guidance has been drafted for the UK context and refers to UK legislation, it can serve as a guide to making such an application to the Minister.

When considering making an application, you may wish to seek independent legal advice. 

Legal advice

Generally, you will not be prohibited from providing legal advice under an asset freeze. However, the payment for legal services and the provision of legal services on credit do require a licence.  

Also, where sanctions prohibit specific actions, for example restructuring of finance, you need to carefully consider whether your advice and support for the client is helping them comply with sanctions or is participating in or facilitating a breach. For example, if it is prohibited to raise capital on financial markets, providing advice on how this affects a business will be permitted. However, preparing documents to raise such capital may amount to an attempt to circumvent sanctions. 

Investments

Generally, you cannot:

• invest your frozen funds
• profit from frozen funds
• move frozen funds from one account to another

The exceptions or existing licensing grounds found in UK Sanctions Regulations are unlikely to allow such activity to be permitted but each application will be considered on a case-by-case basis.

Applications for licences in relation to asset freezes implemented by Jersey legislation will need to demonstrate that such activity is in line with the licensing policy for the relevant regime, for example Russia.

The FSIU’s view is that, in a small number of circumstances, some asset management may be permitted, under the ‘basic needs’ licensing ground, to ensure that the existence of the business or the frozen assets is not imperilled. When considering licensing requests for asset management, the nature and state of the assets at the time of any relevant designation will be considered. It is highly unlikely that requests for new or expanded activity will be permitted but every application is dealt with on a case-by-case basis.

General Licences

UK General Licences

All UK General Licences made under the Russia and Belarus Regimes only, have automatic effect in Jersey and may be relied upon, subject to any necessary modifications.

UK General Licences include reporting requirements which must be adhered to when the licence is relied upon. All persons that rely upon a UK General Licence to undertake specified activities which would otherwise be prohibited by Jersey sanctions legislation must submit all reporting to the Minister at sanctions@gov.je. 

Find a list of active UK General Licences on OFSI General Licence on GOV.UK.

You should be particularly cautious when seeking to rely on Russia or Belarus UK General Licences. Many of the provisions used are drafted for a specific UK context, for example referring to UK legislation. We recommend that you consider taking legal advice before seeking to rely on them.

UK General Licences issued under all other regimes do not apply to Jersey persons or institutions operating in Jersey. However, they may be considered as the basis for a licence application.

Jersey General Licences

A Jersey General Licence, issued by the Minister, allows multiple parties to undertake specified activities which would otherwise be prohibited by sanctions legislation, without the need for a specific licence. However, it is not a substitute for a specific licence. There is no legal basis for the issuance of a Jersey General Licence in place of a specific licence.

Where a general licence is in place to permit an activity, the Minister expects that applicants will make use of this licence. A specific licence will not be issued for the same activity unless the applicant can demonstrate that they are unable to use the general licence or that it is deficient in some way. 

The FSIU does not accept applications for Jersey General Licences. Jersey General Licences are issued by the Minister under such conditions deemed appropriate and will usually be considered in response to unforeseen circumstances where it has been decided that issuing a Jersey General Licence will best support the Government of Jersey’s policy priorities.

For example, a Jersey General Licence could be used to respond to a situation where it may be necessary for persons to undertake otherwise prohibited financial activity because the Government of Jersey has introduced an unrelated financial services policy that would otherwise be hindered by sanctions law, provided that it does not contradict the policy intent of the sanctions regime. 

A Jersey General Licence is not limited to the derogations (licencing grounds) set out in the relevant legislation. Except for UN sanctions regimes, in relation to which a Jersey General Licence would be limited to the derogations set out in the relevant UN resolution. 

A Jersey General Licence can also be issued under the counter-terrorism regimes.

The Minister can vary, suspend or revoke Jersey General Licences at any time.

Each Jersey General Licence will include requirements for, record keeping and reporting. Requirements will be stated in each Jersey General Licence. Reporting must be submitted to the Minister at sanctions@gov.je.

Current Jersey General Licences

Find below the list of Jersey General Licences currently in force.

Date issued	General Licence
27 February 2025	Director Disqualification
5 December 2024	Repayments of Professional Fees - Payments to Revenue Authorities​

It is the responsibility of any party relying on a UK or Jersey General Licence to ensure the activities they undertake fall within the terms of the General Licence and that they comply with any conditions of the General Licence.

As is the case with specific licences, a person commits an offence and is liable to imprisonment for a term of 5 years and to a fine, if the person purports to act under the authority of a Jersey General Licence but fails to comply with any condition to which the licence is subject.

Previous Jersey General Licences

Find below a list of expired or revoked Jersey General Licences.

Date issued​	Date revoked or expired	General Licence
28 June 2023	10 December 2024	Legal Services
30 September 2024	5 December 2024	Payments to Revenue Authorities
3 April 2023	28 June 2023	Legal Services
20 December 2022	3 April 2023	Legal Services​

Applying for a licence

You must provide evidence to:

• support your application
• identify the activity that may be prohibited and the relevant legal provisions within SAFL
• demonstrate that all applicable criteria of the relevant licensing ground have been met

We will return your application if it does not meet these criteria and you’ll have to re-submit it.

The FSIU will endeavour to assist applicants who contact us to understand the licensing process as well as our evidentiary requirements. However, we cannot provide legal advice, and applicants should consider taking independent legal advice before applying, especially for complicated matters.

The FSIU expects that legal and professional advisers will have fully considered the relevant law and formed a view about an application before approaching the FSIU for guidance or submitting an application.

Submitting an application  

Applicants should use the form below to apply for a licence. Send the completed form to sanctions@gov.je​.

Sanctions licence application form​

You should always refer to the up-to-date versions of Jersey’s sanctions legislation on Jersey Legal Information Board (JLIB) and up-to-date relevant UK Sanctions Regulations. Find the links to the UK Sanctions Regulations on the current UK sanctions regimes on GOV.UK.  

Knowingly or recklessly providing false or misleading information in any licence application is taken very seriously. This may result in a criminal prosecution.

You will generally be required to provide: 

• details of the activity that may be prohibited and the relevant legal provisions, such as Article 10 (1) of SAFL
• the licensing grounds being relied upon in the application including supporting arguments
• full information on the parties involved in the proposed transaction, such as the designated persons
• any financial institutions involved, such as the remitter, correspondent and beneficiary
• ultimate beneficiary of the transaction
• the complete payment route including account details
• the amount, or estimated amount, of any proposed transaction

You may wish to seek legal advice to support this process.

Specificity in licensing

In line with international best practice, the FSIU’s view is that compliance with sanctions is generally best served through specificity in licensing about the transactions authorised. Licence applicants should therefore be prepared to provide full details of transactions relevant to their application, including:

• all parties, sums and payment routes involved directly or indirectly in the proposed transactions
• any other relevant information which will assist the FSIU in considering an application

Counter-terrorism regimes

You should email sanctions@gov.je setting out the full details of the proposed transaction if you are seeking a licence under the following regimes:

• ISIL (Da’esh) and Al-Qaida (United Nations Sanctions) (EU Exit)
• Counter-Terrorism (International Sanctions) (EU Exit)
• Counter-Terrorism (Sanctions) (EU Exit) 

Licensing timeframes

The FSIU aims to review all new licensing applications as soon as practicable.

The FSIU will prioritise cases at times of high demand, and in particular where there are issues of personal basic needs or wider humanitarian issues at stake which are of material impact or urgency, or which are deemed to be of particular strategic, economic or administrative importance. If there are particular aspects of your application that you believe make your case especially urgent, make sure you set these out clearly in your application for the consideration of the FSIU.

Licence applications should be submitted to the FSIU well in advance of the date from which the licence is required, with comprehensive supporting information. A completed application is one where the FSIU has received all the information we need to enable us to make a decision about whether there is a legal basis to grant a licence.

We will send back incomplete applications or ask you for additional information until we are satisfied that your application can be considered complete. Complex cases may also require further information from, or dialogue with, other parties including the United Nations and the FSIU equivalents in other jurisdictions where necessary. Failure to submit all the necessary information requested by the FSIU will result in delays to your application being processed.

We are unable to provide individual confirmation of receipt, however, you will receive an automatic response. Once you have submitted your application, the FSIU do not provide updates or discuss the status of the application, unless:

• you are directly asked to provide further information
• there has been a material change of circumstances which may require more immediate review

You should not assume that a licence will be granted or engage in any activities prohibited by financial sanctions until you have received an appropriate licence from the FSIU that has been granted by the Minister. 

Urgent and humanitarian cases

The FSIU will prioritise urgent and humanitarian cases, for example cases that involve a risk of harm or a threat to life.

If a request is urgent, make sure you say so when submitting your application and explain why. Unless an application is genuinely urgent, it will not be treated as such.

Notification and approvals​

The Minister may need to notify or seek approval from the relevant UN Sanctions Committee before issuing a licence. You can find these requirements in the relevant UN Security Council Resolutions.

This may delay the processing time for your application or prevent it from being issued.

Amending licences

Requests for an amendment or variation of a licence should be submitted to the FSIU by email as soon as it is apparent that a change is required. Full supporting information and arguments should be provided.

If multiple amendments need to be made to a single licence, you should group these together into a single request to the FSIU.

The FSIU cannot guarantee that last-minute amendments, or variations will be authorised within the requested timeframe.

Refusal of a licence

If the Minister refuses to issue a licence, the proposed transaction or activities may not be lawful. The FSIU will write giving you the reasons your application has been refused.

Your application may also be refused if you do not require a licence for the proposed transaction or activities.

If you have had an application for a licence refused, you have the following options:  

• ask the Minister to review the decision
  
• re-apply with new or supplementary evidence or new supporting arguments
  
• where applicable, re-apply under a different derogation
  
• seek to challenge the decision in the Royal Court
  

You may wish to seek independent legal advice before taking the matter further. 

Other jurisdictions

Licences issued by the Minister only apply to actions subject to Jersey jurisdiction.

If the prohibited activity engages another jurisdiction, you should consider what provisions you may need to comply with within their requirements. For example, if a payment will pass through several jurisdictions you may need to apply for a licence from each of those countries’ competent authorities.

When considering licensing requests, the Minister will conduct whatever investigation they deem appropriate in the circumstances. This may include consulting with international partners with an interest.

Complying with a licence

Specific licences issued by the Minister are not published. However, the Minister expects licence holders to share licences with other parties to the transaction.

If you are unsure on whether the action you propose to undertake is within the terms of a licence you can seek clarification from the FSIU. 

If you are unsure about the validity of a licence that a designated person or their representative has shown to you, you should email a copy of the licence to sanctions@gov.je.

You should not assume that the FSIU agrees with your interpretation of the licence until you receive a response from us.

Any conduct outside the terms of the licence, such as use of a different payment route or payments in excess of a specific payment cap, is a breach of sanctions, and may result in a criminal prosecution.

Reporting conditions

Licences issued by the Minister come with conditions that often require information to be reported to the Minister within a specific time frame. A failure to comply with any obligation, including reporting obligations, imposed by a licence is an offence.

Reporting under the terms of a licence should be submitted to the Minister at sanctions@gov.je and should clearly demonstrate that the terms have been met. Where appropriate, supporting documents such as bank statements or SWIFT confirmations should be included.

Where more than 1 licence is held, reporting should be submitted separately, with reference to the relevant licence and its terms and conditions.

Legal advisors should proactively engage with their clients about the need to provide information to meet the reporting requirements in licences.

Travelling to Jersey

If you are planning to travel to Jersey and you are:

• a designated person not subject to a travel ban
• a non-designated person funded in whole or in part by a designated person

you should apply for a licence before you travel, to authorise the proposed use of funds or economic resources to support yourself while you are on the Island.  

Export licences​

If you import or export goods, you need to consider if sanctions apply to you.

You may need a licence from the Minister as well as from the UK’s Export Control Joint Unit (ECJU). 

Find more information on Export Control Joint Unit on GOV.UK.​