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Targeted financial sanctions related to terrorism and terrorist financing (TFS-TF)

  • Last revised:21 March 2025

Jersey is committed to implementing all United Nations Security Council (UNSC) and autonomous UK terrorist asset-freeze designations promptly and effectively. Any changes to these UN designations take immediate effect in Jersey.

In alignment with FATF Recommendation 6, this robust sanctions framework restricts designated individuals and entities from accessing funds, financial services or economic resources, while also freezing any existing assets.

UNSC terrorist asset freezes

FATF Recommendation 6 applies to all current and future resolutions succeeding UNSC Resolution 1267 (1999), as well as any forthcoming UNSC resolutions that impose TFS-TF.

The UNSC has established several Committees tasked with responsibilities under Chapter VII of the Charter of the United Nations, including:

  • designating individuals and entities that meet the listing criteria outlined in relevant resolutions
  • considering and deciding upon notifications and requests for exemptions from the sanctions measures
  • assessing and approving requests for designation's name removals from the sanctions List

These Committees periodically review and update their designation criteria to ensure compliance and effectiveness.

To fulfil their mandates, the Security Council Committees issue press releases that amend the relevant sanctions designations lists.

UNSCR 1373 (2001) terrorist asset freezes

The UNSCR 1373 (2001) requires countries to: 

  1. prevent and suppress the financing of terrorist acts
  2. freeze the funds and economic resources of persons who commit or attempt to commit terrorist acts or participate in or facilitate the commission of such acts, and
  3. prohibit their nationals and those within their territories from making funds, financial services, or economic resources available to or for the benefit of such persons.

For UNSCR 1373 (2001), designations are made at the national or supranational level, by a country, or countries, acting on their own motion, or at the request of another country when designation criteria are met.

The relevant asset-freezing designation can be found on the OFSI Consolidated list and the UK Sanctions List.

Jersey implements two counter terrorism regimes that give effect to UNSCR 1373 (2001):

In Jersey, the Minister for External Relations and Financial Services (the Minister) has the power to impose interim and final asset-freezing terrorist sanctions designations under Part 4 of the Sanctions and Asset-Freezing (Jersey) Law 2019 (the SAFL), by assessing the risk and when there is a reasonable suspicion or believe that the person or entity is:

  • an “involved person” under Article 18 of the SAFL and
  • the Minister considers it is appropriate that financial restrictions should be applied in relation to the person for purposes connected with:

(i)  protecting members of the public (whether in Jersey or elsewhere) from terrorism

(ii)      preventing terrorism (whether in Jersey or elsewhere) or

(iii)     otherwise complying with UNSCR 1373 (2001).

However, to date no such designations have been made by the Minister.

“Terrorism”, “act of terrorism” and “terrorist entity” are defined in the Terrorism (Jersey) Law 2002 (the Terrorism Law). “Terrorist activity” is defined in Article 18 of the SAFL.

Under Article 45A of SAFL, the Minister may also make proposals to another jurisdiction for a terrorist asset-freezing designation to be made in that jurisdiction.

Involved person

The Minister must determine whether there are reasonable grounds, or a reasonable basis, to suspect or reasonably believe that the person or entity to which the designation relates:

  • is or has been involved in terrorist activity
  • is an entity owned or controlled (directly or indirectly) by a terrorist entity or a person who is or has been involved in terrorist activity
  • is acting on behalf of or at the direction of a terrorist entity or person who is or has been involved in terrorist activity or
  • is a member of or has pledged allegiance in any way to or is otherwise associated with, a terrorist entity or a person who is or has been involved in terrorist activity.

Terrorist Entity

The term “terrorist entity” means –

  • any entity which commits, prepares, or instigates an act of terrorism, or facilitates the commission, preparation, or instigation of an act of terrorism
  • any proscribed organization.

A list of current proscribed terrorist entities can be found under Schedule 1 of the Terrorism Law or is proscribed by virtue of or under Section 3 of the Terrorism Act 2000 of the UK or operates under the same names as an organisation listed under Schedule 1 of the Terrorism Law.

Sanctions and Asset-Freezing (Jersey) Law 2019 (SAFL)

Article 19 of the SAFL defines a person, group, or entity as a designated person, if he, she, or it:

The United Nations and autonomous UK terrorist asset-freeze designations implemented under Article 19 of the SAFL will appear in the OFSI Consolidated List under the subheading “terrorism/terrorist financing".

Under Article 18 of the SAFL, involvement in terrorist activities includes elements that are similar to some of those in the UK’s Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019 and the Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019, as amended.

Offences

Part 3 of the SAFL contains several prohibitions in relation to designated persons. Those prohibitions are as follows:

  • Dealing with funds or economic resources owned, held, or controlled by a designated person, knowing, or having reasonable cause to suspect such funds or economic resources are being dealt with (Article 10 of the SAFL).
  • Making funds or financial services available (directly or indirectly) to a designated person, knowing, or having reasonable cause to suspect, the funds or financial services are being made so available (Article 11 of the SAFL).
  • Making funds or financial services available to any person for the benefit of a designated person, knowing or having reasonable cause to suspect the funds or financial services are being made so available (Article 12 of the SAFL).
  • Making economic resources available (directly or indirectly) to a designated person, knowing, or having reasonable cause to suspect that the economic resources are being made so available and that the designated person would be likely to exchange the economic resources, or use them in exchange, for funds, goods, or services (Article 13 of the SAFL).
  • Making economic resources available to any person for the benefit of a designated person, knowing or having reasonable cause to suspect that the economic resources are being made so available (Article 14 of the SAFL).
  • Intentionally participating in activities, knowing that the object or effect of such activities (whether directly or indirectly), is to circumvent or facilitate the contravention of any of the above prohibitions (Article 17 of the SAFL).

A breach of any of the prohibitions is a criminal offence carrying a penalty of imprisonment for a term of seven years and a fine. The offences apply to UK nationals ordinarily resident in Jersey and persons incorporated or constituted under the law of Jersey, in respect of conduct committed anywhere in the world.

Article 15 of the SAFL sets out certain exceptions to the prohibitions set out above, for example in relation to credits to a frozen account and the payment of social security benefits.

The prohibitions do not apply to anything done under the authority of a licence granted by the Minister under Article 16 of the SAFL.

Reporting obligations

Under Article 32 of the SAFL, a relevant financial institution must inform the Minister as soon as practicable if:

a) 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

b) 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

c) the information or other matter on which the knowledge or reasonable cause for suspicion is based came to it while carrying on its business.

Such information may be reported to the Minister by e-mail to [email protected] and is in addition to any Suspicious Activity Report (SAR) that may need to be reported separately to the Financial Intelligence Unit (FIU). 

For a relevant financial institution, failure to comply with the obligation to provide information to the Minister is an offence attracting up to 12 months imprisonment and a fine of level 3 on the standard scale.

Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021

The Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (the Jersey Order) was made under the SAFL and came into force on 12 February 2021. It implements all UK sanctions regulations made under the Sanctions and Anti-Money Laundering Act 2018 of the UK.

Alongside the UK Regulations, the Sanctions Order still implements four EU Regulations that prohibit the satisfaction of claims affected by UNCSRs, passed between 1990 and 1994 in relation to Iraq, Libya, Haiti and Serbia and Montenegro. These same measures are implemented in the UK through retained EU legislation.

Where any of the UK Regulations require an asset-freeze, the Jersey Order imposes the standard asset-freeze under Part 3 of the SAFL.

Proscribed organisations and persons connected with terrorism or terrorist financing

Under Article 6 of the Terrorism Law, the Minister for Home Affairs may ‘proscribe’ an organization as being concerned in terrorism.

An organisation is proscribed if:

a) it is listed in Schedule 1 (as amended from time to time) to the Terrorism Law or

b) it operates under the same name as an organization listed in that Schedule or

c) it is proscribed by virtue of or under section 3 of the UK Terrorism Act 2000.

For the purposes of the Terrorism Law, all proscribed organisations are terrorist entities. Part 3 of the Terrorism Law sets out the offences relating to terrorist financing.

Jersey’s Proscribed Organizations list is located in Schedule 1 to Terrorism Law 2002 and follows UK List of proscribed international terrorist groups maintained in the UK under the Terrorism Act 2000. Because proscription involves different restrictions, and because not all proscribed organisations are subject to financial sanctions, the list of proscribed organisations is not included in the OFSI’s Consolidated list.

Financial Sanctions Notices

When there has been a change to the asset-freeze designations in force in Jersey, a Financial Sanctions Notice (Notice) is issued by the Financial Sanctions Implementation Unit ( FSIU)  and published on the Jersey Gazette. You can register to receive email alerts when a new Notice is published.

The JFSC issues sanctions e-mail alerts to those who subscribes to the JFSC website news.

Notices are published when:

  • individuals or entities have been designated for the purpose of an asset-freeze. 
  • individuals or entities are no longer subject to an asset-freeze.
  • the details of existing asset-freeze designations (e.g., identifying information) have been changed.
  • there are other significant changes to Jersey's sanctions regime.

The Notices may include identifying information on asset-freeze designations and what you must do, as well as legislative details and other relevant information.