Sanctions are prohibitions and restrictions put in place with the aim of maintaining or restoring international peace and security. They generally target specific individuals or entities, or particular sectors, industries or interests. They may be aimed at such people and things in a particular country or territory, or some organisation or element within them.
With effect from Tuesday 3 April 2018, reports which are required to be made in respect of financial sanctions must be made to the Financial Intelligence Unit (FIU).
Previously such reports were made to The Customs and Excise Division of the Treasury (CED).
All persons in business or a profession in the Island, including financial institutions, must check whether they maintain any account, or otherwise hold or control funds or economic resources, for individuals or entities named in the published lists having effect in the Island and, if so, they should freeze the account, funds or economic resources and report their findings.
If you suspect that a breach of financial sanctions has occurred, you should report this at the earliest opportunity.
Any person, entity or body with information that would facilitate compliance with the sanctions legislation must supply such information to the FIU and co-operate in any verification of the information.
There are also sanctions that target those persons and organisations involved in terrorism.
More details of the financial sanctions regimes that have effect in the Island are available from the Customs and Excise Website.
Finding the sanctions lists
The Isle of Man does not issue its own lists. Government policy is to maintain the lists of those affected so that they are the same as those designated by HM Treasury in the UK.
How to report
Many businesses on the Island in the regulated sector will already be familiar with the FIU’s online reporting system THEMIS. Those registered to use THEMIS should make their reports via this online system, using the Sanctions option in the Legislation under which disclosure is made drop down menu.
If you wish to report an incident involving an individual or entity on the OFAC sanctions list, please use the Section 24 submission option on Themis.
If you are not registered on Themis, please email firstname.lastname@example.org in the first instance, or contact the FIU on 01624 686000.
An email alerts system is provided by the Office of Financial Sanctions Implementation (Part of HM Treasury).
An RSS feed on the Customs and Excise website enables businesses to receive copies of all news releases relating to sanctions, confirming changes to sanctions measures and lists.
The Sanctions Notices have been updated to reflect the changes.
Please note that any general enquiries or applications for licences or authorisations in respect of financial sanctions should continue to be made to CED.