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This industry update is more than 1 year old

Industry update

Additional trust services sanctions under the Russia sanctions regime

Subject: sanctions

On 21 March 2023, the 1,730 asset-freezing designations under the Russia sanctions regime were additionally designated in respect of trust services sanctions with immediate effect.

Under the Russia (Sanctions) (EU Exit) Regulations 2019, trust services include:

  • The creation of a trust, or similar arrangement;
  • The provision of a registered office, business address, correspondence address; administrative address for a trust or similar arrangement;
  • The operation or management of a trust or similar arrangement; or
  • Acting, or arranging for another person to act, as a trustee of a trust or similar arrangement.

The UK Sanctions List and OFSI’s Consolidated List have been updated to reflect this.

Effects in Jersey

  • Any changes to designations made under the UK Regulations are effective immediately by virtue of the ambulatory provisions in the Sanctions and Asset Freezing (Implementation of External Sanctions) (Jersey) Order 2021.
  • The Government of Jersey issued a Sanctions Notice stating new amendments to the Russian sanctions regime.
  • This means that it is now prohibited to provide trust services to or for the benefit of these designations, unless permitted by a licence or there is an applicable exception. The UK General licence has an automatic effect in Jersey.

Supervised persons
The additional actions you are obliged to undertake have been expanded by the following:

  • check whether you provide any trust services to or for the benefit of designated persons.
  • cease the provision of any trust service(s) to or for the benefit of designated persons unless licensed by the Minister.

You should keep your supervisor informed of any potential sanctions breaches and if required, submit an asset-freeze application form and/or the suspected sanctions compliance reporting form

Further guidance
Visit our Russian sanctions page or Finance industry and Russian sanctions (gov.je) for further guidance. We would also strongly encourage you to subscribe to our sanctions e-mail alerts.