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Jersey Update on Russia Sanctions Reporting Obligations

22/04/2024

The Minister for External Relations ("MER") (the competent authority for sanctions enforcement in Jersey) has updated reporting requirements for RELEVANT FINANCIAL INSTITUTION and DESIGNATED PERSONS in Jersey and as follows.

  1. Regulation 16 of Russia (Sanctions)(EU Exit) (Amendment) (No. 4) Regulations 2023, [https://www.legislation.gov.uk/uksi/2023/1364/regulation/16/made] as reflected in Jersey law according to the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021, https://www.jerseylaw.je/laws/current/Pages/17.750.02.aspx requires Relevant Financial Institutions to report to the MER as soon as reasonably practicable
    1. A "Relevant Financial Institution" is:

                      i. A person [natural or legal] carrying on a financial services business in or from within Jersey, or a person [not being an individual] incorporated or constituted under the laws of Jersey and carrying on financial service business in any part of the world.

  1. Regulation 16 states that Relevant Financial Institutions must report to MER as soon as reasonably practicable if:
    1. It knows or has reasonable cause to suspect it holds funds or economic resources for a prohibited person (i.e. a person designated by Regulation 18A of the UK Russia Sanctions Regulations 2019 - https://www.legislation.gov.uk/uksi/2019/855/regulation/18A  ); and
    2. The information or other matter on which the knowledge or cause for suspicion is based came to it in the course of carrying on business.
  2. Regulation 17 of Russia (Sanctions)(EU Exit) (Amendment) (No. 4) Regulations 2023 requires a DESIGNATED PERSON to self-report to MER any funds or economic resources over the value of £10,000.
    1. This relates to Jersey situs or worldwide assets (if they are ordinarily resident in Jersey [individual] or incorporated or constituted under the laws of Jersey).

The above 16+17 supplement the existing duty on Relevant Financial Institutions under Article 32 of the Sanctions and Asset-Freezing (Jersey) Law 2019 [https://www.jerseylaw.je/laws/current/Pages/17.750.aspx] to report to MER as soon as practicable if:

  1. It holds an account of a person, has entered into dealings or an agreement with a person or has been approached by or on behalf of a person.
  2. It knows or has reasonable cause to suspect that the person –
    1. Is a designated person or
    2. Has committed, is committing or intends to commit an offence under this Law; and
  3. The information or other matter on which the knowledge or reasonable cause for suspicion is based came to it while carrying on its business.

Sources

JERSEY SANCTIONS

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As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.  

news disclaimer -

As well as owning and publishing Comsure's copyrighted works, Comsure wishes to use the copyright-protected works of others. To do so, Comsure is applying for exemptions in the UK copyright law. There are certain very specific situations where Comsure is permitted to do so without seeking permission from the owner. These exemptions are in the copyright sections of the Copyright, Designs and Patents Act 1988 (as amended)[www.gov.UK/government/publications/copyright-acts-and-related-laws]. Many situations allow for Comsure to apply for exemptions. These include 1] Non-commercial research and private study, 2] Criticism, review and reporting of current events, 3] the copying of works in any medium as long as the use is to illustrate a point. 4] no posting is for commercial purposes [payment]. (for a full list of exemptions, please read here www.gov.uk/guidance/exceptions-to-copyright]. Concerning the exceptions, Comsure will acknowledge the work of the source author by providing a link to the source material. Comsure claims no ownership of non-Comsure content. The non-Comsure articles posted on the Comsure website are deemed important, relevant, and newsworthy to a Comsure audience (e.g. regulated financial services and professional firms [DNFSBs]). Comsure does not wish to take any credit for the publication, and the publication can be read in full in its original form if you click the articles link that always accompanies the news item. Also, Comsure does not seek any payment for highlighting these important articles. If you want any article removed, Comsure will automatically do so on a reasonable request if you email info@comsuregroup.com.