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Russian Federation

  • Last revised:28 November 2025

Purpose of the Sanctions Regime

This sanctions regime is aimed at encouraging Russia to cease actions which destabilise Ukraine, including actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine.

Overview of current sanctions measures

Current sanction measures implemented by Jersey in relation to the Russia include, but not limited to:

  • asset freezes and restrictions on making funds and economic resources available to and for the benefit of designated persons
  • financial and other investment restrictions, including prohibitions relating to transferable securities or money market instruments, prohibitions relating to loans and credit arrangements, and investments in Crimea
  • prohibitions against the import, export, supply and delivery, making available, or transfer of military goods, military technology, dual-use goods, and dual-use technology
  • prohibitions against the provision of technical assistance, financial services and funds, or brokering services, relating to military goods, military technology, dual-use goods, and dual-use technology
  • restrictions on energy-related goods and related activities
  • restrictions relating to exports and imports certain goods, products
  • prohibition of provision certain services, including legal advisory services
  • transport sanctions
  • travel ban
  • director disqualification sanctions
  • technology transfer sanctions
  • sectoral software sanctions

Overview of financial sanctions measures

Asset freeze and making available provisions

This sanctions regime imposes financial sanctions through a targeted asset freeze on designated persons and prohibitions on making funds or economic resources available. This involves the freezing of funds and economic resources (non-monetary assets, such as property or vehicles) of designated persons and ensuring that funds and economic resources are not made available to or for the benefit of designated persons, either directly or indirectly.

Other financial and investment restrictions

This sanctions regime prohibits a person from directly or indirectly dealing with a transferable security or money market instrument if it has a maturity exceeding 30 days, and was issued after 1 August 2014 by:

  • Sberbank, VTB bank, Gazprombank, Vnesheconombank (VEB), Rosselkhozbank
  • an entity incorporated or constituted in a country other than the UK which is owned by one or more of the five banks listed above
  • an entity acting on behalf of or at the direction of those five banks named above or an entity incorporated or constituted in a jurisdiction other than Jersey which is owned by one or more of those five banks.

It is also prohibited for a person to directly or indirectly deal with a transferable security or money market instrument if it has a maturity exceeding 30 days, and was issued after 12 September 2014 by:

  • OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft or Gazprom Neft
  • an entity incorporated or constituted in a jurisdiction other than Jersey which is owned by one or more of the six entities listed above
  • an entity acting on behalf of, or at the direction of, those six entities named above or an entity incorporated or constituted in a jurisdiction other than Jersey which is owned by one or more of those six entities.

It is prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument if it has a maturity exceeding 30 days, and was issued on or after 1 March 2022 by:

  • a person connected with Russia
  • an entity owned by such persons
  • an entity acting on behalf or at the direction of any of the above.

It is also prohibited for a person to directly or indirectly deal with a transferable security or money-market instrument which was issued on or after 1 March 2022 by the Government of Russia.

For designations made, see Russia: list of persons named in relation to financial and investment restrictions.

Loan and credit arrangements

This sanctions regime prohibits a person from directly or indirectly granting or entering into any arrangement to grant a new loan or credit, with a maturity exceeding 30 days to:

  • Sberbank, VTB bank, Gazprombank, Vnesheconombank (VEB), Rosselkhozbank, OPK Oboronprom, United Aircraft Corporation, Uralvagonzavod, Rosneft, Transneft or Gazprom Neft
  • an entity incorporated or constituted in a jurisdiction other than Jersey which is owned by one or more of the entities listed above
  • an entity acting on behalf of or at the direction of the entities listed above or an entity incorporated or constituted in a jurisdiction other than the Jersey which is owned by one or more of those entities.

It is also prohibited for a person from directly or indirectly granting or entering into any arrangement to grant a new loan or credit to the Government of Russia on or after 1 March 2022.

Correspondent banking relationships and sterling payments

This sanctions regime prohibits correspondent banking relationships and processing sterling payments to, from or via, a designated person if the relevant financial institution knows, or has reasonable cause to suspect, that the correspondent banking relationship is with a designated person. This prohibition applies to payment chains or third party payments.

Provision of financial services for the purpose of foreign exchange reserve and asset management

On or after 1 March 2022, it is prohibited to provide financial services for the purpose of foreign exchange reserve and asset management to:

  • Central Bank of the Russian Federation, National Wealth Fund of the Russian Federation, Ministry of Finance of the Russian Federation
  • a person owned or controlled, acting on behalf of or at the direction of any of the above, directly or indirectly.

Investments in relation to non-government controlled Ukrainian territory

This sanctions regime prohibits:

  • directly or indirectly acquiring, extending a participation, or acquiring any ownership interest in land located in non-government controlled Ukrainian territory
  • directly or indirectly acquiring, extending a participation, or acquiring any ownership interest in an entity which has a place of business located in non-government controlled Ukrainian territory (Relevant Entity)
  • directly or indirectly granting any loan or credit, entering into any arrangement to grant a loan or credit or otherwise provide funds, including equity capital, to a relevant entity or for the purpose of financing the Relevant Entity
  • directly or indirectly establishing any joint venture in non-government controlled Ukrainian territory or with a Relevant Entity
  • providing investment services directly related to the activities referred to above

Investments in relation to Russia

This sanctions regime prohibits:

  • direct acquisition of any ownership interest in Russian land and persons connected with Russia
  • indirect acquisition of any ownership interest in Russian land and persons connected with Russia for the purpose of making funds or economic resources available directly or indirectly to, or for the benefit of, persons connected with Russia
  • direct or indirect acquisition of any ownership interest in entities with a place of business in Russia (which are not persons connected with Russia) for the purpose of making funds or economic resources available directly or indirectly to, or for the benefit of, persons connected with Russia
  • establishing joint ventures with a person connected with Russia
  • opening representative offices and establishing branches and subsidiaries in Russia; or
  • the provision of investment services directly related to all activities above

Trust Services

On or after 16 December 2022, the regime prohibits:

  • the provision of trust services to or for the benefit of persons designated for the purposes of this measure, and
  • the provision of trust services to or for the benefit of persons connected with Russia unless those services were provided immediately prior to 16 December 2022 pursuant to an arrangement that has effect at that time

Trust services means:

  • the creation of a trust or similar arrangement
  • the provision of a registered office, business address, correspondence address or administrative address for a trust or similar arrangement
  • the operation or management of a trust or similar arrangement
  • acting or arranging for another person to act as trustee of a trust or similar arrangement
  • acting as a nominee shareholder 

Suspension of Banking Act 2009 requirement to recognise third-country resolution actions

This regime disapplies the Bank of England’s statutory duty under section 89H(2) of the Banking Act 2009 to make a decision in respect of recognition notifications from third-country resolution authorities where:

  • the resolved bank or financial institution is a designated person subject to an asset freeze; or
  • the resolved bank or financial institution is owned or controlled directly or indirectly by such a designated person

This means that the Bank of England will not make a decision under section 89(H)(2), that is to recognise, partially recognise or refuse to recognise a third-country resolution action, for as long as the resolved institution in question is designated as subject to an asset freeze or is owned or controlled directly or indirectly by a person who is designated as subject to an asset freeze under the Russia Regulations.

Latest news

28 November 2025

The UK Sanctions List has been updated. All current asset-freezing sanctions designations effective in Jersey are available on the OFSI Consolidated List of financial sanctions targets. Further information can be found on Jersey Gazette. 

19 November 2025

The UK Sanctions List has been updated. All current asset-freezing sanctions designations effective in Jersey are available on the OFSI Consolidated List of financial sanctions targets. Further information can be found on Jersey Gazette. 

*All published Latest News notices relating to financial sanctions, including those extending beyond the last 30 days, may be obtained from the Jersey Gazette

Jersey regime

The Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (the Jersey Sanctions Order) implements the Russia (Sanctions) (EU Exit) Regulations 2019 (the UK Regulations).

Article 3 of the Jersey Sanctions Order imposes the asset-freeze provisions in Part 3 of the Sanctions and Asset-Freezing (Jersey) Law 2019 (the SAFL) on any person listed by or under the UK Regulations. The Part 3 provisions also include, but are not limited to, Articles 15-17 of the SAFL on exceptions, licences, and circumventing prohibitions etc.

Since 29 September 2022, the UK amendments and general licences to Russia sanctions regime have an automatic effect in Jersey, subject to the general modification provisions of the Jersey Sanctions Order. The Minister can grant a General Licence that expressly modifies or disapplies a UK General Licence. The Minister can also disapply a UK General Licence altogether, without making any replacement.

Offences

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

Reporting obligations

Reporting obligations are set out at Article 32 of the SAFL and apply to all regimes in force. These obligations include requirements for a relevant financial institution to inform the Minister if:

  • 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, and
  • it knows, or has reasonable cause to suspect, that the person:
    • is a designated person, or;
    • has committed, is committing or intends to commit an offence under the SAFL, and
  • the information or other matter on which the knowledge or reasonable cause for suspicion is based came to it in the course of carrying on its business.

Additional reporting obligations were imposed on relevant financial institutions and designated persons on 26 December 2023 by Regulations 16 and 17 of The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023. 

The approved reporting forms are available on Sanctions forms for licences and suspected breach notifications.

Licences and exceptions

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 [email protected].

The FSIU provides guidance on sanctions licences and exceptions on the Government of Jersey website Sanctions licences and exceptions.

Legal acts

Jersey

  • Sanctions and Asset-Freezing (Jersey) Law 2019
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Amendment – Russia) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Russia -Amendment No.2) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Russia -Amendment No. 3) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Russia -Amendment No. 4) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Russia -Amendment No.5) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Russia -Amendment No.6) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Russia - Amendment No.7) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Russia - Amendment No.8) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Russia - Amendment No.9) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Russia - Amendment No.10) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Implementation of External Sanctions) (Exceptions and Licences - Amendment) (Jersey) Order 2022
  • Sanctions and Asset-freezing (Implementation of External Sanctions) (Amendment – Automatic Implementation of UK Sanctions on Russia) (Jersey) Order 2022
  • Sanctions and Asset-Freezing (Amendment of Law and Order No. 2) (Jersey) Order 2023

United Kingdom

  • The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2025 
  • The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2024 
  • The Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2024 
  • The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2024 
  • The Sanctions (EU Exit) (Miscellaneous Amendments and Revocations) Regulations 2024 
  • The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2024
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.5) Regulations 2023.
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.4) Regulations 2023.
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2023.
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.2) Regulations 2023.
  • The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2023
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.17) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.16) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.15) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.14) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.13) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.12) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.11) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.10) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No. 9) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No. 8) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No. 7) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No. 6) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) (No. 2) Regulations 2022
  • The Russia (Sanctions) (EU Exit) (Amendment) Regulations 2022
  • The Russia (Sanctions) (EU Exit) Regulations 2019
  • The Sanctions (EU Exit) (Miscellaneous Amendments) (No.2) Regulations 2020
  • The Sanctions (EU Exit) (Miscellaneous Amendments) (No.4) Regulations 2020

Further information

The Government of Jersey:

Useful information and guidance links:

Sanctions evasion typologies examples:

 Further Information on financial sanctions targets is provided on GOV UK