On 24 May 2024 the UK Government updated it’s Syria sanctions regime Syria (Sanctions) (EU Exit) Regulations 2019 ('the 2019 Regulations') as a result of The Syria (Sanctions) (EU Exit) (Amendment) Regulations 2024 (the 'UK Amendment Regulations').
The new measures set out in the UK Amendment Regulations became effective immediately in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024 (the 'Regulations') which are made under the Sanctions Act 2024.
The UK Amendment Regulations included changes to the humanitarian exception to improve the overall efficiency and usability of the humanitarian exception, helping to improve the delivery of humanitarian aid in Syria.
The amendments include the expansion of the categories of eligibility for reliance on the humanitarian exception to include a wider list of organisations ('relevant persons').
Financial service providers of relevant persons (and those providing funds or economic resources to such persons) are authorised to use the humanitarian exception, removing the requirement for financial service providers to apply for individual licences to facilitate activities authorised by the exception.
The existing notification requirement is removed for use of the humanitarian exception for petroleum prohibitions in the 2019 Regulations and adds a new notification requirement for relevant persons using the humanitarian exception, requiring them to notify the Treasury on an annual basis if they are conducting humanitarian assistance activities in Syria. Certain eligible organisation, including financial service providers, are exempt from reporting requirements.
Failure to comply with financial and trade sanctions legislation or attempting to circumvent its provisions is a criminal offence.
How to make a report
Reports under these measures should be submitted to the Financial Intelligence Unit ('FIU'). 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.
If you are not registered on Themis, please contact the FIU in the first instance by email at fiu@gov.im.
Further Information
Further details of sanctions may be found on the Sanctions and Export Control pages of the Isle of Man Government website.
Contact details for enquiries
If you require any further information or guidance, please contact the Sanctions Team on:
Telephone: +44 1624 648109
Email: sanctions@gov.im
Please note: We are unable to provide legal advice. You may need to seek independent legal advice.
