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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 and UN 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

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.

All these restrictions apply in Jersey.

Russia sectoral measures

These changes to sanctions have extended some of the investment and financial restrictions on Russian companies and introduced some new measures.

These 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
  • extending the prohibitions on securities and money-market instruments
  • extending the prohibitions on issuing loans and credit
  • trade and aviation sanctions measures

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 an offence under the Jersey sanctions legislation.
Sanctions Compliance Reporting Form

Assets reported and frozen

The Minister for External Relations and Financial Services has 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, initially on a monthly basis. The figure for June will be published in July.

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

  • In line with the reporting obligations of financial institutions, 150 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 £1,068,800,000.

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 page. 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 are not implemented in Jersey. However, a UK general licence can form the basis of a licence application to the Minister.

Other information

A recording of a webinar, jointly run by Jersey Financial Services Commission and the Government of Jersey, provides background information.

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

Questions about Russian sanctions

Are Russian nationals allowed to hold entities or property in Jersey?

There is no blanket ban on Russian nationals, but many designations currently in force, and more are likely. The financial services industry - and particularly those dealing with Russian customers or assets linked to Russia and Belarus – are expected to be considering the risk status of their relationships and where there may be relevant links to Russian assets.

What do we do if we have a client who was born in Russia but has no other contact with their domicile of birth?

At the moment there is no requirement to notify the Minister for External Relations and Financial Services of a Russian national other than those who fall within the scope of the reporting obligations described above.

Do sanctions apply to family relations of designated individuals?

It depends. At times, sanctions regimes may designate family members specifically and it is important to understand the specific requirements under the regime. In general, however, it may not be the case. It would always be advisable to be aware of close family of business arrangements that may exist so that indirect benefits can be effectively mitigated.

Asset freezing restrictions do not automatically apply to the relatives of a designated person unless they are named. However you must carefully consider on a case by case basis any direct or indirect sanctions risk.

Is there currently any limit on the amounts that may be held in bank accounts by Russian nationals?

There are no limits currently in force locally. We are working with the UK government and will provide updates in due course if any come into force.

What steps should a designated non-financial business or profession (DNFPB) take if they find they are dealing with a designated person?

The sanctions apply to designated non-financial business or profession (DNFPBs) as they do to any person, natural or legal. No person, association or organisation may deal with funds or economic resources owned, held or controlled by a designated person. DNFBPs should also be mindful of their reporting obligations in respect of sanctions currently in force.

What is a UK general licence, and do they apply in Jersey?

These are licences issued by the UK government which permit an act which would otherwise be a breach of sanctions obligations.

They do not apply in Jersey, but may form the basis for a local application.

What is a UK exception, and does it apply in Jersey?

An exception provision also permits an act which would otherwise be a breach of sanctions.

UK exceptions to asset freeze restrictions do not apply locally but may also  form the basis for a local application. UK exceptions to other sanctions restrictions are implemented in Jersey, but you should seek independent legal advice before acting in reliance of any UK exception.

What is the timescale for notifying the Minister?

You should do so as soon as is practicable.

If we wish to resign from a relationship with a designated person where there are no assets to freeze, should we notify the Minister using the reporting form?

Yes.

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