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Small amendments to cyber sanctions in the UK and Jersey

13/08/2025

On 12 August 2025, the UK government issued an update to its Cyber Sanctions regime under the Cyber (Sanctions) (EU Exit) Regulations 2020, which are part of the broader framework established by the Sanctions and Anti-Money Laundering Act 2018.

Jersey followed this UK update:

Here's a summary of the key changes:

🔐 What Was Amended?

  1. Duplicate Entries Removed:
    • Aleksey Sergeyevich Morenets (Group ID: 16995)
    • Yevgeniy Mikhaylovich Serebriakov (Group ID: 17000)
    • These were removed from the Consolidated List due to duplication[1][2].
  2. Original Entries Amended:
    • Morenets (Group ID: 13906) and Serebriakov (Group ID: 13907) remain subject to asset freezes.
    • Their statements of reasons were updated:
      • Morenets was linked to a 2018 cyberattack attempt on the Organisation for the Prohibition of Chemical Weapons (OPCW).
      • Serebriakov’s affiliation was updated from GRU Unit 26165 to Unit 74455, with broader allegations of cyber activity undermining UK and international security[3].

🧾 What You Must Do (If You're a Financial Institution or Entity):

  • Check for any accounts or assets linked to these individuals.
  • Freeze such assets immediately.
  • Refrain from dealing with or making assets available to them unless licensed.
  • Report any findings to the Office of Financial Sanctions Implementation (OFSI) or Jersey’s MER [1][2].

⚠️ Ransomware Guidance:

The notice also reiterates that facilitating ransomware payments to designated individuals could result in civil or criminal penalties, and refers to updated government guidance on this issue[1].

References

[1] Cyber - GOV.UK https://assets.publishing.service.gov.uk/media/689afdaea6eb81a3f9b2e354/Notice_Cyber_120825.pdf

[2] Financial Sanctions Notice Cyber 12 August 2025 https://www.gov.je/gazette/Pages/FinancialSanctionsNoticeCyber12August2025.aspx

[3] UK amends sanctions lists | Global Sanctions https://globalsanctions.com/2025/08/uk-amends-sanctions-lists/

JERSEY UNITED KINGDOM CYBER 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.