ASK MAT - The Sanctions and Asset-Freezing (Automatic Implementation of UK Sanctions) (Jersey) Amendment Order 2025 came into force on 5 December 2025. What do I need to do?

ASK MAT –

• The Sanctions and Asset-Freezing (Automatic Implementation of UK Sanctions) (Jersey) Amendment Order 2025 came into force on 5 December 2025. What do I need to do as a Jersey TCSP?
• I'm asking with specific reference to the requirement that establishes a Jersey-specific annual reporting deadline for submitting asset-freezing reports to the Minister by 31 March each year.

MAT's Quick Answer

• With specific reference to the Jersey-specific annual reporting deadline for submitting asset-freezing reports to the Minister by 31 March each year,   
• There is no requirement to submit a report (including a nil return) if you hold no frozen funds or economic resources owned, held, or controlled by a designated person.
• However, the obligation is triggered only by knowledge or reasonable suspicion of holding such assets.
• The first report (if applicable) would be due by 5:00 p.m. on 31 March 2026, covering assets as of close of business on 31 December 2025.
• This annual requirement is separate from any immediate or event-based reporting duties under the Sanctions and Asset-Freezing (Jersey) Law 2019.
• If circumstances change and you suspect or confirm holding frozen assets in the future, you must report promptly and include them in subsequent annual reports.

A More Comprehensive Overview

• The Sanctions and Asset-Freezing (Automatic Implementation of UK Sanctions) (Jersey) Amendment Order 2025 came into force on 5 December 2025, primarily streamlining the application of UK sanctions in Jersey.
• Previously, new or updated UK prohibitions and obligations under the listed sanctions regimes required specific amendments to Jersey's Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021.
• Now, these apply automatically in Jersey (with limited exceptions where equivalent or conflicting Jersey provisions already exist) across 36 specific UK sanctions regimes, such as those targeting countries like Russia, Belarus, and Iran, as well as thematic regimes like global human rights or cyber sanctions. The Minister for External Relations retains the ability to modify or disapply specific elements if necessary.

COMSURE

• You can see COMSURE’s post from 2/12/2025 here:- https://www.comsuregroup.com/news/sanctions-legislation-update-annual-reporting-of-frozen-assets-02-december-2025
• Also, additional information follows

General Impact on Individuals and Businesses in Jersey

• Compliance with Sanctions:
• If you operate in Jersey (as an individual, company, or entity undertaking activities here), you must comply with existing sanctions prohibitions, such as not dealing with frozen assets or providing funds or economic resources to designated persons.
• This amendment does not introduce new prohibitions but ensures that future UK changes, such as new asset freezes, trade restrictions, or obligations, take effect automatically without delay.
• Continue screening transactions, clients, and assets against updated UK sanctions lists (available via the UK government's Office of Financial Sanctions Implementation (OFSI) or Jersey's equivalent resources) to avoid breaches.
• No Action Needed for Most People:
• If you do not hold or control any funds or economic resources owned, held, or controlled by designated persons under these regimes, this law has minimal direct impact beyond reinforcing existing compliance duties.
• Jersey residents and businesses are already subject to these sanctions, and the automation primarily affects administrative processes for the government.

Key New Obligation: Annual Asset-Freezing Reports

The amendment introduces a Jersey-specific annual reporting requirement for frozen assets, aligning it with the local financial year rather than the UK's original deadlines. This applies to holdings under the 36 implemented UK regimes.

• Who Must Report: Any person (individual or legal entity) subject to Jersey sanctions legislation who knows or has reasonable cause to suspect they hold frozen funds or economic resources owned, held, or controlled by a designated person. This includes:
• Individuals and legal persons within Jersey or undertaking activities here.
• Jersey-incorporated or registered bodies, including their overseas branches.
• In practice, this often affects financial institutions (e.g., banks, trust companies, investment firms), but it extends to anyone holding such assets (e.g., lawyers, accountants, or private individuals with relevant holdings).
• What You Need to Do:
• Submit a report to the Minister for External Relations by 5:00 p.m. on 31 March each year, detailing any frozen assets held as of close of business on 31 December of the previous year.
• The first such report is due by 5:00 p.m. on 31 March 2026 (for assets as of 31 December 2025).
• Use the official annual frozen assets reporting template (Jersey Frozen Asset Reporting Template 2025, available for download from the Jersey government website) and email it to AnnualFrozenAssetReporting@gov.je.
• Include details such as the nature, amount or value, and location of the assets, plus any additional information that could aid compliance.
• This is in addition to any immediate or event-based reporting obligations (e.g., under Article 32 of the Sanctions and Asset-Freezing (Jersey) Law 2019, where relevant financial institutions must report suspicions promptly).
• If You Hold No Frozen Assets: There is no need to submit a nil return or any report if you do not hold such assets.
• Penalties for Non-Compliance: Failing to report is a criminal offence. Depending on the breach, penalties can include up to 7 years' imprisonment and/or an unlimited fine for contraventions of prohibitions or obligations under the UK regimes implemented. Lesser information-related offences (e.g., failing to provide requested details) may carry a maximum of 12 months' imprisonment and a fine, or up to 2 years' imprisonment for certain obstructions or false information.

If your situation involves specific holdings, business activities, or uncertainties (e.g., whether an asset qualifies as frozen), consult a legal advisor or the Jersey Financial Services Commission for tailored guidance. This is general advice based on the legislation and should not be construed as legal advice.

Web Sources

1. https://www.gov.je/gazette/pages/sanctionslegislationupdateautomaticimplementationofuksanctions02122025.aspx
2. https://www.jerseyfsc.org/industry/international-co-operation/sanctions/sanctions-and-asset-freezing-law
3. https://www.harneys.com/our-blogs/regulatory/sanctions-update-automatic-implementation-in-jersey
4. https://www.comsuregroup.com/news/sanctions-legislation-update-annual-reporting-of-frozen-assets-02-december-2025
5. https://www.gov.je/gazette/Pages/FinancialSanctionsNoticeAnnualFrozenAssetsReportingJersey.aspx
6. https://www.jerseylaw.je/laws/enacted/Pages/RO-089-2025.aspx
7. https://www.jerseyfsc.org/industry/international-co-operation/sanctions/sanctions-and-asset-freezing-law
8. https://www.gov.je/gazette/pages/sanctionslegislationupdateannualreportingoffrozenassets02december2025.aspx
9. https://www.gov.je/gazette/Pages/FinancialSanctionsNoticeAnnualFrozenAssetsReportingJersey.aspx
10. https://www.jerseylaw.je/laws/current/Pages/17.750.aspx
11. https://www.jerseyfsc.org/industry/international-co-operation/sanctions/financial-sanctions-practical-guidance
12. https://www.amatilaw.com/briefings-blog/overview-international-sanctions-in-jersey
13. https://www.gov.je/Industry/Finance/FinancialCrime/Sanctions/pages/sanctionsimplementation.aspx
14. https://www.jerseyfsc.org/industry/international-co-operation/sanctions/sanctions-forms-for-licences-and-suspected-breach-notifications