The applied Russia (Sanctions) (EU Exit) (Amendment) (No. 5) Regulations 2023 create prohibitions, subject to certain exceptions, on — the import, acquisition and supply and delivery of diamonds and diamond jewellery which are located, originate in or are consigned from Russia, and the provision of ancillary services relating to the diamond prohibitions.
Amendments being made by the application of the Russia (Sanctions) (EU Exit) (Amendment) (No. 4) Regulations 2023 include inserting prohibitions in relation to the import or acquisition of certain Russian-origin metals including copper, nickel, aluminium and zinc, with some exceptions, as well as the addition of a power to Treasury which would enable it to grant a licence for certain activities carried out by an Isle of Man entity in order to get rid of assets located in Russia, where those assets are subject to sanctions.
The sanctions will also extend the prohibition on Isle of Man credit or financial institutions from processing sterling payments, from or via Russian state-owned bank PJSC Sberbank or Novikombank a Russian bank, (directly or indirectly) to include any other currency, subject to certain exceptions.
There will also be the addition of new reporting obligations on relevant firms, and designated persons themselves, in relation to funds and economic resources that person owns or controls, the creation of penalties for breach of the obligations, and the power for the Treasury to impose civil monetary penalties for breach of the obligations.
The first iteration of sanctions on Russia were introduced in 2022, but have been updated in line with the UK, with the latest amendments in the UK being imposed in December 2023.
Additionally, sanctions on Iran include the imposition of asset freezes on funds and economic resources of designated persons; a ban on the export of military goods and restrictions on the provision of military technology and associated services inclusive of unmanned aerial vehicles; and the prohibition of ships owned, controlled, chartered or operated by a designated person inclusive of the prohibition of a specified ship from entering ports in the Isle of Man.
A UK Government spokesperson said: ‘The sanctions regime has been developed to respond to unprecedented threats from the Iranian regime, including efforts to undermine peace and security across the Middle East and plots to kill individuals on UK soil,’
An Isle of Man Government spokesperson added: ‘If the island were not to implement the Iran Regulations, it could have a negative reputational impact, a detrimental effect on our relationship with the UK and could mean that the list of individuals and entities subject to the sanctions regimes are out of line with the UK making it difficult for island businesses and persons to be clear on their obligations.’