General Trade licence – IOM/2023/GTL002
The Treasury has the power to issue General Trade Licences for financial and trade sanctions regimes under a number of Regulations.
On 22 February 2023, the Treasury issued General Trade Licence GTL002 under regulation 61 and 62 of the Syria (Sanctions) (EU Exit) Regulations 2019, as they apply to the Isle of Man by the Syria Sanctions (Application) Regulations 2020 [SD 2020/0503] (“the Syria Regulations”).
On 04 July 2023, the Treasury issued a revised version of the Licence which is identical to the previous licence with the exception that it will remain in force until it is revoked. A description of the licence is below.
Sanctions do not target humanitarian aid, food, or medical supplies, but the current requirements for individual licencing are not always practical during a crisis response and these General Licences will further facilitate earthquake relief efforts in Syria. They will strengthen the timely and effective delivery of relief efforts by removing the need for individual licence applications and should provide extra clarity to actors on the ground responding to this devastating earthquake.
Any persons intending to use the General Licences should consult copies of the Licences for full details of the permissions and usage requirements which can be found attached to this release.
General Trade Licence IOM/2023/GTL002 will extend the protection offered by the current humanitarian exception to petroleum prohibitions for Isle of Man-funded persons to all those conducting earthquake relief efforts in Syria and Turkey. This covers persons delivering the specified activities and their service providers.
For the purposes of General Licence IOM/2023/GTL002 –
- Provider means any legal or natural person including financial institutions or other financial services providers located in or operating from within the Isle of Man or which is an Island person operating anywhere in the world engaging in any activity authorised by the licence.
- Island person means –
- a British citizen, a British overseas territories citizen, a British National (Overseas) or a British overseas citizen who is resident in the Isle of Man;
- a person who under the British Nationality Act 1981 (of Parliament) is a British subject who is resident in the Isle of Man;
- a British protected person within the meaning of that Act who is resident in the Isle of Man; or
- a body incorporated under the law of the Isle of Man
Under General Licence IOM/2023/GTL002 subject to the conditions set out in the licence, authorises direct or indirect acquisition, supply or delivery of petroleum products which originate, located in or are from a person connected with Syria if the activity is exclusively for the purposes of facilitating humanitarian assistance in relation to earthquake relief efforts in Syria and Turkey.
Notification Requirements
General Trade Licence IOM/2023/GTL002 includes a notification and record keeping requirement that within 30 calendar days of the first use of this licence, the provider must provide details to the Treasury, of the name and address at which records are kept in relation to this licence. Records must be kept for a period of 4 years.
General
The permissions in the General Licences do not authorise any act which the person carrying out the act knows, or has reasonable grounds for suspecting, will result in funds or economic resources being made available in breach of the Syria Regulations, save as permitted under licences granted under the Syria Regulations.
Further details of the sanctions regime related to Syria may be found on the Customs and Excise pages of the Isle of Man Government website.
