Jersey Sanctions and asset-freezing law overview [JFSC refreshed guidance 10/3/25]

Background

• The JFSCs Jersey Sanctions and asset-freezing law overview Issued guidance on 19 July 2019 and Last revised: 10 March 2025

Jersey sanctions framework

• The Sanctions and Asset-Freezing (Jersey) Law 2019 (the SAFL) came into force on 19 July 2019. 
• The Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (the Jersey Order) was made under the SAFL on 29 January 2021 and came into force on 12 February 2021.
• The SAFL and the Jersey Order are the Island's key pieces of sanctions legislation, under them, the Island implements all
  • The United Nations Security Council and 
  • Autonomous UK sanctions regimes.
• Also, the Jersey Order still implements
  • Four 'EU claims Regulations' prohibiting the satisfaction of claims affected by UN Security Council Resolutions passed between 1990 and 1994 concerning
    • Iraq,
    • Libya,
    • Haiti,
    • Serbia and Montenegro.
  • These 'EU claims the UK has not implemented Regulations' under its own sanctions legislation and have instead been retained in EU legislation.
• Where UK Regulations require an asset freeze,
  • The Jersey Order imposes the standard asset freeze under Part 3 of SAFL.

Amendments

• On 19 October 2019, the Sanctions and Asset-Freezing (Amendment) (Jersey) Law 2019  came into force. It amended some general provisions.
• On 8 June 2022, the Sanctions and Asset-Freezing (Amendment No. 2) (Jersey) Law 2022 came into force. It amended the SAFL provisions regarding:
  • Reporting obligations.
  • Civil immunities provision.
  • Definitions for the terms 'owned, held, controlled, directly and indirectly';
  • Meaning of terrorism and related terms.
• On 17 July 2023, the Sanctions and Asset-Freezing (Amendment No.3) (Jersey) Law 2023 came into force. It made changes to provisions related to:
  • Licences and exceptions.
  • Terrorist asset-freeze designations.
  • Implementation of UN asset-freezing designations.
  • Reporting obligations and the Minister’s powers to require information.
  • Extra-territorial extent.
  • Requests for UNSC asset-freezing designation and requests for assistance with UN delisting.
  • Regulation-making power;
  • Remove power to implement EU Sanctions by Order.
• On 30 March 2023, the Sanctions and Asset-Freezing (Amendment of Law and Order) (Jersey) Order 2023 came into force with amendments of the SAFL definitions under Articles 2.
• On 18 September 2023, the Sanctions and Asset-Freezing (Amendment of Law and Order No 2) (Jersey) Order 2023 came into force with further amendments of the SAFL definitions under Article 2(A).
• On 14 December 2023, the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Iran —Amendment) (Jersey) Order 2023 came into force, further amending Iran sanctions regimes.
• On 5 December 2024, the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Amendment Order 2024 came into force, amending certain sanctions regimes related to Burundi and the DPRK.
• On 27 February 2025, the Sanctions and Asset-Freezing (Implementation of External Sanctions – Director Disqualification) (Jersey) Amendment Order 2025 came into force by introducing Director disqualification sanctions in Jersey.

Offences

• The offences for this regime are set out in both the SAFL and the Jersey Order. 

Industry: licences and breaches

• A Jersey General Licence, granted by the Minister, allows multiple parties to conduct specified activities that sanctions measures would otherwise restrict.
• Supervised persons must ensure that their activities are within the scope of the General Licence's terms and adhere to all its conditions.
• The Minister may also grant a specific licence under the SAFL and/or the Jersey Order.
• To apply for a specific sanctions licence, a supervised person must complete the relevant Sanctions form and return it to sanctions@gov.je.
• The FSIU provides guidance on sanctions licences and exceptions on the Government of Jersey website Sanctions.
• Suspected breaches of sanctions compliance must be reported to the Minister by completing the Sanctions Compliance Reporting Form. Once completed it must be returned to sanctions@gov.je.