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Automatic Implementation of UK Sanctions on Russia

Published byExternal Relations
Date published
22 September 2022

On Thursday 22 September 2022, the Minister for External Relations (the "Minister") made the Sanctions and Asset-freezing (Implementation of External Sanctions) (Amendment – Automatic Implementation of UK Sanctions on Russia) (Jersey) Order 2022  (the "Amendment Order").

The Amendment Order will come into force on Thursday 29 September.

The Amendment Order will amend the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 ("Sanctions Order") to provide for automatic implementation of future amendments to the UK's Russia (Sanctions) (EU Exit) Regulations 2019 (the "UK Russia Regulations"). It also provides for the automatic implementation of UK General Licences made under the UK Russia Regulations in relation to non-asset-freezing prohibitions only.


If the UK amends the UK Russia Regulations to add a new prohibition or obligation, then the existing Jersey offence of breaching implemented sanctions provisions (carrying imprisonment for up to 7 years and an unlimited fine) will apply automatically to a breach of that new prohibition or obligation in Jersey.

There will therefore be no need for the Sanctions Order to be amended again to implement new UK prohibitions and obligations made under the UK Russia Regulations. However, the Minister retains the power to modify or disapply a particular prohibition or obligation by amending the Sanctions Order.

The other effect of the Amendment Order is that if the UK grants a General Licence under the UK Russia Regulations, then that General Licence (and any conditions imposed on it by the UK) will have automatic effect in Jersey in relation to non asset-freeze prohibitions only. Any provisions relating to asset-freezing prohibitions will not apply automatically.

The Minister can grant a General Licence that expressly modifies or disapplies a UK General Licence. The Minister can also disapply a UK General Licence altogether, without making any replacement.


The Russia sanctions guidance and sanctions licences and exceptions guidance on will be updated to reflect these changes.

Additional guidance on sanctions can be found on both the Government of Jersey and Jersey Financial Services Commission  websites. If you have any questions about this notice or new guidance, please contact

Automatic Implementation of UK Sanctions on Russia
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