ASK MAT – Does the JFSC/MFSC advise that NOT being on a sanction list doesn’t mean there is no sanction!

ASK MAT – Does the JFSC/MFSC advise that NOT being on a sanction list doesn’t mean there is no sanction!

MAT SAYS:-

• Yes, both the Mauritius Financial Services Commission (FSC) and the Jersey Financial Services Commission (JFSC) have issued explicit warnings that just because an entity is not on a published sanctions list does not mean it is not subject to sanctions risk.
• This is especially relevant in the context of indirect exposure, reputational risk, and sanctions evasion typologies.

Firstly, both would also consider the 50% rules for any UK sanctions (legally compelled), as well as EU/US sanctions. The 50% Rule means that:

• Any entity owned 50% or more—directly or indirectly, individually or in aggregate—by one or more sanctioned persons is itself considered sanctioned, even if it is not named on a sanctions list.

Jersey law and JFSC Guidance.

• Sanctions and Asset-Freezing (Jersey) Law 2019 - Page 44

• The JFSC enforces both UK and UN sanctions, and its guidance confirms that:
  • “Entities may be indirectly sanctioned through ownership or control, even if not named. The 50% rule applies to UK sanctions and must be considered in all risk assessments.”—  https://www.jerseyfsc.org/industry/international-co-operation/sanctions/
• The JFSC has issued similar warnings, stating:
  • “Entities may be indirectly involved in sanctioned activity even if not themselves designated. The risk of breaching Jersey’s sanctions regime remains high in such scenarios.”
    — JFSC Registry Sanctions Guidance https://www.jerseyfsc.org/registry/registry-high-risk-and-sanction-information/
• They further note that:
  • Indirect ownership, historic activity, or group affiliations with sanctioned jurisdictions (e.g., Russia, Iran, North Korea) can trigger scrutiny.
  • Restructuring transactions involving such entities must be fully disclosed and risk-assessed, even if the entities are not on a list.

Mauritius FSC Guidance

• The FSC Mauritius has emphasised that:
• “The absence of a name on a sanctions list does not imply that a person or entity is free from sanctions risk.
• Entities may still be involved in activities that support sanctioned parties or regimes, including proliferation financing or sanctions evasion.”
  — FSC Targeted Sanctions Guidance  Implementation of Targeted Sanctions - Financial Services Commission https://www.fscmauritius.org/en/aml/amlcft/implementation-of-targeted-sanctions
• This aligns with the UN Sanctions Act 2019, which allows Mauritius to act against entities not yet listed but reasonably suspected of supporting sanctioned activities.

ALSO - The Mauritius Financial Services Commission (FSC) has taken enforcement actions against multiple entities in 2025, including the suspension and revocation of Global Business Licences (GBLs)

These actions:-

• Appear aimed at addressing risks such as proliferation financing (PF), sanction evasion, and
• Are often linked to international sanctions imposed by bodies such as the EU, UK, and US, and
• Tied to restricted activities, including:
1. Russian oil transport or
2. Dealings with designated groups (e.g., the Houthis).

The FSC’s actions go beyond UN sanctions, incorporating EU, UK, and US designations, in line with FATF Recommendation 7 and the UN Sanctions Act 2019. And it is understood [see links below] that the FSC applies Section 74(5) of the Financial Services Act 2007 (as amended) when revoking the licences.  74[5] provides the FSC with broad powers to revoke a GBL if it's deemed necessary to safeguard Mauritius's reputation as a financial centre, prevent harm to the integrity of the financial services sector, or protect the public.

74[5] says:-

• “Where the Commission is satisfied on reasonable grounds that the revocation of the Global Business Licence is necessary to protect the good repute of Mauritius as a centre for financial services,
• To prevent or mitigate damage to the integrity of the financial services industry or any part thereof, or to protect the public in general, it may revoke a Global.

Confirmed Suspended/revoked Entities:

The initial suspensions (a precursor to potential revocation) have often cited Section 74(6)(a), which bars suspended entities from conducting business without FSC approval and

The FSC is progressively revoking licenses of entities found to be in breach of sanctions or PF-related obligations.

1. Angat Shipping Incorporated – Revoked on 2 September 2025 https://www.fscmauritius.org/media/201771/notice-for-publication_angat.pdf
2. Bicol Shipping Incorporated – Revoked on 2 September 2025 https://article.wn.com/view-electricity/2025/09/03/02_Sep_2025_FSC_Mauritius_issues_Public_Notice_Revocation_of/
3. Campana Shipping Incorporated – Revoked on 2 September 2025 https://www.fscmauritius.org/media/201777/notice-for-publication_campana.pdf
4. Tigwa Shipping Incorporated – Revoked on 2 September 2025 https://www.fscmauritius.org/media/206486/19-notice-for-publication_tigwa.pdf
5. Bagsak Shipping Incorporated (suspended separately in May 2025) – Revoked on 1 September 2025 https://www.fscmauritius.org/media/201790/bagsak-notice-to-publish-revocation.pdf
6. Sapang Shipping Incorporated – Revoked on 2 September 2025 https://www.fscmauritius.org/en/media-corner/public-notice
7. Naga Shipping Incorporated = Revoked on 30 September 2025 https://www.fscmauritius.org/media/206478/10-notice-for-publication_naga.pdf
8. Davao Shipping Incorporated  = Revoked on 30 September 2025 https://www.fscmauritius.org/media/206462/4-notice-for-publication_davao.pdf
9. Morong Shipping Incorporated Revoked on one October 2025 https://www.publicnow.com/view/784927B42D467599CBE7A6745DC0F905F685B05F
10. Aklan Shipping Incorporated
11. Elizario Shipping Incorporated
12. Ragang Shipping Incorporated
13. Tirad Shipping Incorporated
14. Tunasan Shipping Incorporated

Connections to Sanctions: Many of these entities have ties to activities evading Western sanctions, such as transporting Russian oil or trading with Houthi-controlled areas. For instance:

• Sapang Shipping Inc. (and its registered agent, Redbird Corporate Services Ltd.)

• Was hit with EU sanctions on July 18, 2025, for undermining Ukraine's sovereignty via high-risk shipping practices, including flag-hopping, AIS manipulation, and lacking proper insurance on its tanker ARGENT.
• The FSC followed up with a suspension on July 21, 2025, and a complete revocation on September 2, 2025.
• Sapang is linked to Mauritius's ABC Group and the Ah-Chuen family.
• https://www.comsuregroup.com/news/sapang-shipping-inc-loses-its-mauritius-registered-agent-redbird-corporate-services-due-to-eu-sanctions-on-both/
• Bagsak Shipping Incorporated
• Faced US OFAC sanctions on April 28, 2025, for secondary risks under Executive Order 13224, related to Houthi support via cargo discharges in restricted ports.
• The FSC suspended its authorisation on May 2, 2025.
• https://www.comsuregroup.com/news/mauritius-under-us-scrutiny-for-sanction-busting/

Context and Implications

• These companies were allegedly involved in complex maritime trade routes, dual-use goods, or front operations that masked sanctions evasion or proliferation financing.
• Some were linked to Russian oil exports and support for sanctioned entities such as the Houthis (Ansarallah) in Yemen.
• The FSC’s actions go beyond UN sanctions, incorporating EU, UK, and US designations, in line with FATF Recommendation 7 and the UN Sanctions Act 2019.

Regulatory Significance:

This marks a notable shift in Mauritius’ enforcement posture, signalling:

• Increased international cooperation
• A move to protect the jurisdiction’s reputation as a financial centre
• A warning to Corporate and Trust Service Providers (CTSPs) and Global Business License holders to enhance due diligence

These moves align with Mauritius's efforts to maintain its status following its exit from the FATF grey list, emphasising compliance with global sanctions regimes. The FSC's enforcement manual highlights the potential for revocation under 74(5) for protecting integrity, which aligns with sanction-related risks.  

Web Links (Sources Used)

Revoked as of 3 October 2025

Here are the web source links referenced above, listed for easy copying:

References

• Mauritius proliferation financing (PF) risk is a REAL AND PRESENT ...https://www.comsuregroup.com/news/mauritius-proliferation-financing-pf-risk-is-a-real-and-present-danger-following-the-fsc-suspension-of-13-licences/
• https://www.comsuregroup.com/news/mauritius-proliferation-financing-pf-risk-is-a-real-and-present-danger-following-the-fsc-suspension-of-13-licences/
• https://www.fscmauritius.org/en/media-corner/communiques
• https://www.fscmauritius.org/en/others/news
• https://newsmoris.com/2025/07/20/eu-imposes-sanctions-on-2-mauritius-firms-linked-to-russian-oil-trade/
• http://www.comsuregroup.com/news/sapang-shipping-inc-loses-its-mauritius-registered-agent-redbird-corporate-services-due-to-eu-sanctions-on-both/