The Sanctions Act 2024 (‘the Act’) comes into operation on 01 May 2024.
The Act, and the Sanctions (Implementation of UK Sanctions) Regulations 2024, provide the legislative framework for how United Nations and United Kingdom Sanctions are given legal effect in the Isle of Man.
What are Sanctions
Sanctions are prohibitions (bans) and restrictions put in place with the aim of maintaining or restoring international peace and security.
Sanctions can be imposed by the United Nations or countries acting on their own or together with others. For the purposes of the Act this specifically means sanctions imposed by the United Nations and the United Kingdom.
There are different types of sanctions:
- Financial – impose asset freezes against individuals and entities; bans on providing certain financial services
- Trade – import/export bans on certain goods, related services and technologies
- Transpot – bans and restrictions on certain aircraft and ships and related services
- Immigration – travel bans – banning the entry into the UK (including the Isle of Man) of certain individuals
What does this have to do with me
If you answer ‘yes’ to any of the following questions, then the sanctions rules may apply to you:
- Do you trade in goods or services internationally?
- Are you regulated by the Financial Services Authority or Gambling Supervision Commission?
- Do you send or receive funds or financial services internationally?
You should check carefully whether any sanctions prohibitions or restrictions apply to you or your business. If you are in any doubt, you should seek independent legal advice.
Failure to comply with the sanctions rules is an offence, which could result in a monetary fine or a prison sentence.
What is changing
This is a technical change to how sanctions are given legal effect in the Island. There are no changes to the prohibitions and restrictions currently in place.
Sanctions have legally been in place in the Island for a number of years through :
- Numerous Regulations made under the European Union and Trade Act 2019
- The Terrorism and Other Crime (Financial Restrictions) Act 2014, or
- Orders made under the Sanctions and Anti-Money Laundering Act 2018 (a UK Act)
The Act brings together the majority of UN and UK sanctions legislation under one Act of Tynwald, and into one set of Regulations instead of being separated over a number of Acts and Regulations.
A webinar is available to explain in detail the new legislative changes.
Where can I find further information
Guidance is currently available on the Sanctions and Export Control webpage from 1 May 2024 on the redesigned webpages.
Individuals and entities subject to sanctions can be found in the UK Sanctions List.
Contact details for enquiries
If you require any further information or guidance in relation to Sanctions, please contact the Sanctions Team on:
Telephone: +44 1624 648109
Email: sanctions@gov.im
