Implementation of Russia sanctions in Jersey
The UK Russia (Sanctions) (EU Exit) Regulations 2019 (UK Russia Regulations) impose a broad range of measures to encourage Russia to cease actions which destabilise Ukraine, including actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine. Measures imposed under the UK Russia Regulations include:
- financial sanctions, such as asset-freezes
- non-financial sanctions, including restrictions on trade in goods and services, transport and immigration
The UK Russia Regulations on legislation.gov.uk
Jersey acts in line with the UK on matters of foreign policy and implements all UK sanctions deployed in response to Russia's actions. The UK Russia Regulations are implemented in Jersey under the
Sanctions and Asset-Freezing (Jersey) Law 2019 (SAFL) and the
Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (the Sanctions Order).
Jersey’s sanctions legislation applies to Jersey, and it also applies to conduct by Jersey persons, both nationals and corporate bodies, outside of Jersey. This includes UK sanctions regulations implemented in Jersey.
The following guidance provides a summary of some key aspects of the implementation of the UK’s Russia Regulations in Jersey.
This guidance does not represent legal advice
If you are unsure about your obligations in any given case, you should consider taking independent legal advice.
Russia financial sanctions
The UK Russia regulations impose a number of prohibitions and obligations that are implemented automatically in Jersey. In addition to asset freezes, which are common among other sanctions regimes, under the UK’s Russia regulations restrictions include additional unique measures that restrict access to capital markets, clearing services and dealing in reserves for Russian state-owned financial institutions. They also detail restrictions on investments in relation to the Republic of Crimea and the city of Sevastopol.
The UK’s Office of Financial Sanctions Implementation (OFSI) publishes the following detailed guidance on the UK’s Russia sanctions regime
Find supplementary guidance on OFSI's
UK Financial Sanctions FAQs on GOV.UK.
The UK guidance provided in the links above 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 or regime. If you are unsure about your obligations in a given case, you should consider seeking independent legal advice.
Find more guidance on
Russian Federation's sanctions on Jersey Financial Services Commission (JFSC).
Designations under the Russia sanctions regime
When there has been a change to any asset-freeze designations under the Russia regime, External Relations issue and publish a Financial Sanctions Notice in the Jersey Gazette (Notice). To receive an email alert when a new Notice is published, complete the registration form.
The following also provide an up-to-date list of persons designated for the purposes of the UK Russia Regulations:
All UK sanctions designations are immediately effective in Jersey.
Find more guidance on listing and de-listing on
international sanctions in Jersey.
Asset freezes
An asset-freeze designation is a type of targeted financial sanction that requires anyone holding a listed person's funds or economic resources to freeze them. ‘Person' can refer to both individuals and legal entities.
As well as the designated persons themselves, these prohibitions apply to persons who are owned, held or controlled by a designated person.
Find more guidance on complying with asset-freeze and reporting obligations in Jersey on
international sanctions in Jersey.
Virtual 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? on blog.gov.je
Reporting obligations
The requirement for a Relevant financial Institution (RFI) to report to the Minister in the case of connections to a designated person, and breaches or attempted breaches of sanctions is set out in
Article 32 of SAFL. It applies to all sanctions regimes in force including the Russia Regime.
Find more guidance on complying with asset-freezes and reporting obligations, including a the reporting form, on international sanctions in Jersey.
Additional reporting obligations for Russia and Belarus regimes
The following additional reporting requirements for RFI’s under the Russia Regime, and for designated persons under the Russia and Belarus Regimes, have been introduced. These reporting requirements are effective in Jersey subject to the general modifications provisions of the
Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021.
Immobilised assets reporting requirements (Russia regime)
In accordance with regulation 70(1ZA) of the Russia Regime, a RFI is required to inform the Minister as soon as practicable, if it knows, or has reasonable cause to suspect, that it holds funds or economic resources for any of the following, and the information or other matter on which the knowledge or cause for suspicion is based came to it in the course of carrying on its business:
- The Central Bank of the Russian Federation
- The National Wealth Fund of the Russian Federation
- The Ministry of Finance of the Russian Federation
- a person owned or controlled directly or indirectly by these entities, or
- a person acting on behalf of or at the direction of these entities
To comply with this requirement, email the completed Immobilised Assets Reporting Form and any associated documents to
sanctions@gov.je.
Immobilised assets reporting form
Where a RFI knows, or has reasonable cause to suspect, that it holds any such funds or economic resources as listed above, it is also required to submit an annual report to the Minister for so long as those funds or economic resources continue to be held. The annual report must be made by 30 November in each year as to the nature and amount or quantity of funds and economic resources held by that firm as of 30 September in that calendar year.
Designated person reporting requirements (Russia and Belarus regimes)
If you are a designated person under the Russia (Sanctions) (EU Exit) Regulations 2019 or under the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019, you’re required to disclose to the Minister any funds or economic resources you:
These requirements require designated persons to provide the Minister with details of their Jersey assets (or their worldwide assets if they are Jersey Persons). A Jersey Person in this context is an individual who is ordinarily resident in Jersey, or a person incorporated or constituted under the law of Jersey.
The UK Russia Regulations require a report to be provided within 10 weeks of the relevant date, which is either:
- 10 weeks after the date the legislation came into force on 26 December 2023 (Russia Regime) or 16 May 2024 (Belarus Regime)
- 10 weeks after the date of your designation if you were designated after either the 26 December 2023 (Russia Regime) or 16 May 2024 (Belarus Regime)
Use the following forms to comply with this reporting obligation:
Designated person reporting template for Jersey persons
Designated person reporting template for non-Jersey persons
Designated persons must report any funds or economic resource if the value of those funds or economic resources exceeds the value of £10,000. If multiple funds or economic resources of the same type (for example, jewellery, art, bank accounts), taken together exceed £10,000, this must also be reported.
Email a completed version of the relevant form with any additional attachments you wish to provide to
sanctions@gov.je. Make sure you sign the declaration in Part 5 before submitting the form.
Assets reported and frozen
The Minister for External Relations remains committed to publishing the value of the assets reported to him as frozen under the Russia sanctions regime.
The following figure is accurate as of 30 April 2025 to the best of the Minister's knowledge at the time of publication:
in line with the reporting obligations of financial institutions, 428 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 £1,388,300,000 (rounded to the nearest £100,000)
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
- certain financial activity being licensed
Asset-freeze licences and exceptions
There are exceptions to some of the asset freezing provisions which apply within certain defined circumstances set out at
Article 15 of the SAFL and the UK Russia Regulations.
You should be particularly cautious when seeking to use exceptions in the UK Russia Regulations, as they may have been drafted for a specific UK context, such as referring to UK legislation. We recommend that you consider seeking independent legal advice before relying on such exception.
Where a designated person’s assets have been frozen, the designated person or a representative may apply for a licence from the Minister to enable an otherwise prohibited use of frozen funds or economic resources, in certain circumstances.
Find further guidance on
sanctions licences and exceptions.
General licences
Jersey General Licences
Find details of any current
Jersey General Licences issued by the Minister which may authorise certain activity under the Russia regime.
UK General Licences
On 18 September 2023, the
Sanctions and Asset-Freezing (Amendment of Law and Order No. 2) (Jersey) Order 2023 (GL Order) came into force. The GL Order provides for the automatic effect in Jersey of all UK General Licences made under the UK Russia Regulations, subject to any necessary modifications.
We strongly recommend you review the list of active UK General Licences under the Russia Regime prior to submitting a sanctions licence application. Find the list of
OFSI General Licences on GOV.UK.
Many of the provisions used in UK General Licences are drafted for a specific UK-context, such as referring to UK legislation. It is recommended that you consider taking legal advice before seeking to rely on them.
All reporting requirements also apply to the UK General Licence. Reports should be submitted to the Minister at
sanctions@gov.je in line with the terms of the licence.
Additional 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
Professional and business-related services
Regulation 54C of the UK Russia Regulations, as implemented in Jersey, prohibits providing certain professional and business-related services to Russia-connected persons. However, there is an exemption to enable the fulfilment of statutory and regulatory obligations in respect of these prohibitions. The exemption is detailed in Regulation 60DA of the UK Russia Regulations.
The exemption under Regulation 60DA is also implemented in Jersey.
Guidance on complying with professional and business services sanctions related to Russia on GOV.UK
The UK guidance is drafted for the UK context and should be read in conjunction with Jersey sanctions legislation/regime. The information provided is intended as a practical guide for professionals and businesses potentially affected by the regulations. However, it does not constitute legal advice. Any party in doubt about its legal position should seek independent legal advice.
Oil price cap
The Oil Price Cap on Russian crude oil came into effect in Jersey and the UK on 5 December 2022. The equivalent restrictions and exceptions for refined oil products came into effect on 5 February 2023.
Find detailed
UK maritime services ban and oil price cap industry guidance on GOV.UK. This includes information on general and specific licences to facilitate specified activities on
Russian oil services ban on GOV.UK.
UK General Licences made under
The Russia (Sanctions) (EU Exit) Regulations 2019 on legislation.gov.uk have automatic effect in Jersey. Reliance upon UK General Licences, reporting of any suspected breaches, and applications for specific licences in connection with the Oil Price Cap must be submitted to Jersey's Minister for External Relations.
Suspected breach reporting forms on GOV.UK
Further guidance and advisories on GOV.UK related to the Oil Price Cap include:
Specification of ships
The
UK Russia Regulations 2019 on legislation.gov.uk provide that the UK Secretary of State may specify a ship for the purposes of shipping sanctions if the ship is, has been, or is likely to be, involved in a relevant activity (as defined in regulation 57F of the UK Russia Regulations).
The UK Sanctions List on GOV.UK provides details of the:
- ships specified under the UK Russia Regulations
- sanctions in respect of which they have been specified
gov.je