JFSC and Government of Jersey gave a presentation on 6 December on how UN and EU sanctions are implemented in and affect Jersey businesses.
Key points that may not always be as prominent as they should be:-
- The process for suspected sanctions breaches to Minister For External Relations externalrelations@gov.je
- The need to obtain a license from the Minister to pay monies etc that would otherwise be in breach of a sanction (assuming such power is with the Minister). The rationale for such a payment may be stipulated in the sanction and include medical treatment or similar humanitarian purposes.
- The danger of time lags between a sanction taking effect under the UN and then taking effect in the EU, UK and Jersey due to legislation being brought into effect in those other jurisdictions.
- The JFSC is working on a new sanctions website that should be more user friendly in terms of guidance etc. The current pages have not been altered for some 11 months.
See the slides HERE