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Finance industry and Russian sanctions

Jersey acts in line with the UK on matters of foreign policy, and has implemented all UK sanctions deployed in response to Russia's actions. These are autonomous sanctions which are wide-ranging and include asset freezing designations which target persons both legal and natural with restrictions on assets and services.

Financial, trade, shipping and immigration sanctions have been imposed against Russia for its invasion of Ukraine.

All persons (natural and legal) must comply with sanctions prohibitions, and all financial institutions have responsibility for monitoring and ensuring compliance with sanctions which are implemented in Jersey by the Minister for External Relations.

Government and the JFSC continue to engage with stakeholders during this period and is monitoring the situation closely. The JFSC has already published an initial update to their Russia guidance page

We will continue to publish important updates on the Jersey Gazette and you should sign up for e-alerts.

Russia sanctions: guidance

Detailed guidance on the UK sanctions regime against Russia can be found on the Office of Financial Sanctions Implementation's Russia guidance page.

Sanctions and restrictions

The UK has imposed sanctions on hundreds of new persons (legal and natural), including President Putin and Russia's foreign minister Sergey Lavrov. The measures included travel bans and asset freezes and will prevent those targeted from conducting business within the UK and Jersey.

  • the UK Sanctions List sets out the persons designated under UK sanctions Regulations made under the UK Sanctions and Anti-Money Laundering Act 2018, and details of the sanctions in respect of which they have been designated.
  • the Office of Financial Sanctions Implementation maintains the separate OFSI Consolidated List, which names all persons designated by the UK for the purpose of an asset-freeze.
  • OFSI also has a list of Russian entities named in relation to financial and investment restrictions
  • All UK sanctions designations are immediately effective in Jersey.

All these restrictions apply in Jersey.

Russia sectoral measures

Sanctions that cover investment and financial restrictions on Russian companies  include:

  • measures to prevent Russian banks from clearing payments in sterling
  • measures that prohibit transactions with the Central Bank of the Russian Federation, Russian Ministry of Finance and Russian National Wealth Fund
  • prohibitions on securities and money-market instruments
  • prohibitions on issuing loans and credit
  • trade, aviation and shipping sanctions measures
  • prohibitions on energy-related goods and related activity

Crypto assets

Crypto assets are an economic resource, and as such are caught by Jersey's sanctions legislation. Attempting to circumvent sanctions using crypto assets is prohibited in the same way that it would be for any traditional fiat currency. Any reports of suspected non-compliance should be reported to the Minister in the same way.

Russian sanctions: can you sanction Crypto?

Reporting obligations

Any person who conducts a financial services business in Jersey, or any legal person incorporated or constituted under the law of Jersey that carries on such business in any part of the world, must report as soon as practicable if it has reasonable cause to believe that it holds an account, has entered into dealings or an agreement with, or been approached by or on behalf of a person who is a designated person or who has committed, is committing or intends to commit an offence under the Jersey sanctions legislation.

Sanctions Compliance Reporting Form

Assets reported and frozen

The Minister for External Relations remains committed to publishing regular updates on the value of the assets reported to him as frozen under the Russia sanctions regime. Updates will be published on a quarterly basis. The figure for Q3 2022 will be published in October.

The following figure is rounded to the nearest £100,000 and provided in aggregate. It is accurate as of 31 July 2022 to the best of the Minister's knowledge at the time of publication:

  • In line with the reporting obligations of financial institutions, 178 sanctions compliance reports have been submitted to the Minister in connection with the Russia sanctions regime.
  • The reports concern a number of issues relating to sanctions compliance, including, but not limited to, assets that have been frozen.
  • The reports of frozen assets received by the Minister totalled £1,157,300,000.

Where reports have been received of assets frozen in currencies other than pounds, they have been converted. The value of assets reported as frozen in Jersey may fluctuate for numerous reasons, including changes to asset-freeze designations, further investigation to verify or clarify the value of assets, additional information being reported, or certain financial activity being licensed.

Licensing

It is possible to apply for a licence to undertake certain activities that would otherwise be prohibited. Details are available on the sanctions licences and exceptions. However, the grounds available for making a licence application will vary depending on which activity you wish to undertake and therefore you are advised to consider taking independent legal advice before making a licence application.

The UK general licences issued by OFSI under the UK Russia regime cover various activities such as allowing financial institutions to wind down their positions in Russian banks.

UK General Licences made under the UK Russia regime apply automatically in Jersey for provisions in respect of non-asset-freeze only. Those provisions in relation to asset-freezing prohibitions do not apply; however, they may be considered as the basis for a licence application

Other information

A recording of a webinar, jointly run by Jersey Financial Services Commission and the Government of Jersey is available online. Link provided below.

Joint risk statement to the financial services industry: Customer relationships associated with Russia and Belarus
Russian sanctions regime webinar
How sanctions are implemented
General sanctions information on the JFSC website


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