ASK MAT - Is Zimbabwe a sanctioned exposed jurisdiction in the UK/Jersey

ASK MAT - Is Zimbabwe a sanctioned exposed jurisdiction in the UK/Jersey

Mat says:-

• Jersey maintains its sanctions framework through two primary instruments:
• Sanctions and Asset-Freezing (Jersey) Law 2019 (SAFL) AND
• Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (SAFO)
• Jersey does not compile its own separate list. Instead, it adopts the UK Sanctions List (maintained by the FCDO) and the OFSI Consolidated List for asset-freeze designations.
• All UN and UK designations apply in Jersey immediately via “ambulatory provisions” in SAFL and SAFO—meaning updates to UK or UN lists automatically take effect in Jersey without further local legislation. [jerseyfsc.org]

Taking a look at the above and Zimbabwe's status, I can advise that the Current Status (as of May 2025) is:-

• The UK maintains an arms embargo on Zimbabwe embargo is part of the Zimbabwe (Sanctions) (EU Exit) Regulations 2019, implemented under the Sanctions and Anti-Money Laundering Act 2018. [gov.uk]
• However, the UK removed the last entries from its Zimbabwe sanctions list in May 2025, including four individuals and one entity (Zimbabwe Defence Industries). [gov.uk]
  • the trade restrictions and arms embargo remain in force
• There are currently no UK asset-freeze targets linked to Zimbabwe, but the legal framework remains in place for future designations. [globalsanctions.com]

• • The UK maintains an arms embargo on Zimbabwe, which prohibits:
    • Export, supply, delivery, and transfer of military goods and technology.
    • Provision of technical assistance, brokering, and financial services related to such goods. [gov.uk]

Even though the UK removed all financial sanctions designations for Zimbabwe in May 2025, the trade restrictions and arms embargo remain in force. [globalsanctions.com]

As noted above, Zimbabwe is included in the UK list of countries subject to arms embargoes and trade restrictions.[gov.uk]

So, even though the JFSC Appendix D2 – Countries and territories identified as presenting higher risks - Last revised: 24 October 2025 shows a HIT in source 6, I cannot find any evidence of any sanctions although source 12 is correct

https://www.jerseyfsc.org/media/ez0jpmk1/appendix-d2-october-2025.xlsx

BRIEFING ON SAFL/SAO AND ZIMBABWE (SANCTIONS) (EU EXIT) REGULATIONS 2019

1. Core Legislation

• Sanctions and Asset-Freezing (Jersey) Law 2019 (SAFL)
  This is the primary law that gives Jersey the power to implement international sanctions and asset-freezing measures. It covers:
• Designation of persons and entities.
• Asset-freeze obligations.
• Licensing and exceptions.
• Reporting duties and enforcement powers. [jerseyfsc.org]
• Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (SAFO)
  This Order enables Jersey to automatically implement all UN Security Council sanctions and UK autonomous sanctions regimes. It also retains some legacy EU measures (e.g., claims regulations for Iraq, Libya, Haiti, Serbia, Montenegro). [comsuregroup.com]

2. How Jersey Maintains Its Sanctions Lists

• Jersey does not compile its own separate list. Instead:
• It adopts the UK Sanctions List (maintained by the FCDO) and the OFSI Consolidated List for asset-freeze designations.
• All UN and UK designations apply in Jersey immediately via “ambulatory provisions” in SAFL and SAFO—meaning updates to UK or UN lists automatically take effect in Jersey without further local legislation. [jerseyfsc.org]
• Jersey also maintains:
• A Proscribed Organisations list under the Terrorism (Jersey) Law 2002, aligned with the UK’s list of proscribed terrorist groups. [jerseyfsc.org]

Operational Process

• Financial Sanctions Notices are issued by Jersey’s External Relations Department and published in the Jersey Gazette whenever:
• New designations are added.
• Existing designations are amended or removed.
• These notices mirror UK updates and provide local compliance guidance. [ezine.ever…erland.com]
• The JFSC will update its D2 list - Appendix D2 – Countries and territories identified as presenting higher risks - Last revised: 24 October 2025
• https://www.jerseyfsc.org/media/ez0jpmk1/appendix-d2-october-2025.xlsx

Zimbabwe (Sanctions) (EU Exit) Regulations 2019

The UK sanctions regime for Zimbabwe is governed by the Zimbabwe (Sanctions) (EU Exit) Regulations 2019, made under the Sanctions and Anti-Money Laundering Act 2018. Here’s a clear summary:

Purpose

The sanctions aim to encourage the Government of Zimbabwe to:

• Respect democratic principles and institutions.
• Refrain from actions that repress civil society and democratic opposition.
• Comply with international human rights law and respect human rights. [gov.uk]

Types of Sanctions

1. Financial Sanctions
• Asset freezes on designated individuals and entities.
• Prohibition on making funds or economic resources available to them. [gov.uk]
2. Trade Sanctions
• Restrictions on the export, supply, delivery, and transfer of military goods and technology.
• Ban on providing technical assistance, financial services, or brokering related to restricted goods. [gov.im]
3. Immigration Sanctions
• Travel bans on designated individuals. [gov.uk]
4. Other Measures
• Director disqualification for designated persons. [gov.uk]

Current Status (as of May 2025)

• The UK removed the last entries from its Zimbabwe sanctions list in May 2025, including four individuals and one entity (Zimbabwe Defence Industries). [gov.uk]
• There are currently no UK asset-freeze targets linked to Zimbabwe, but the legal framework remains in place for future designations. [globalsanctions.com]

Legal References

• • Zimbabwe (Sanctions) (EU Exit) Regulations 2019 [legislation.gov.uk]
  • UK Sanctions List [assets.pub…ice.gov.uk]
  • Financial Sanctions Guidance [gov.uk]
  •  https://ezine.eversheds-sutherland.com/global-sanctions-guide/jersey
  • https://globalsanctions.com/region/zimbabwe/