Key amendments to the Sanctions and Asset Freezing (Jersey) Law 2019 come into force

Key amendments to the Sanctions and Asset Freezing (Jersey) Law 2019 (SAFL) came into force on 18 March 2026. The changes are part of Jersey’s continuing efforts to ensure its sanctions framework remains robust, clear and closely aligned with international standards, in particular the UK regime. 

Taken together, the amendments are intended to remove areas of uncertainty for industry, strengthen enforcement and information sharing, and support effective cross-border cooperation in the implementation of sanctions. 

Clarification of 'indirect' dealings with designated persons 

A new Article 9A has been inserted into the SAFL to clarify the scope of the existing prohibitions on making funds, financial services or economic resources available indirectly to, or for the benefit of, a designated person. 

The new provision confirms expressly that these prohibitions extend beyond the designated person themselves and apply equally where funds, economic resources or financial services are made available to any person who is directly or indirectly owned or controlled by a designated person. This brings greater clarity to an area that has historically required careful interpretation, particularly in complex ownership and control structures. 

In practice, the amendment reinforces the need for firms to look beyond formal legal ownership and consider questions of control and influence when assessing sanctions risk. It underlines the importance of robust due diligence, ongoing monitoring and a clear understanding of group structures and beneficial ownership. 

Updated reporting obligations for financial institutions

Article 32(1) has been amended to further align Jersey’s reporting obligations with those under UK sanctions legislation. The changes remove certain pre-reporting requirements that were specific to the Jersey regime. 

As a result, a relevant financial institution must now, as soon as practicable, report to the Minister for External Relations any knowledge or reasonable cause to suspect, arising in the course of carrying on its business, that a person is a designated person or has committed, is committing or intends to commit an offence under the SAFL. 

This amendment simplifies the reporting process and reduces potential delays in the flow of information to the authorities. It also places renewed emphasis on the need for firms to have effective internal escalation and reporting procedures so that suspicions are identified and reported promptly. 

Expanded information sharing powers for the Minister

New Articles 36(1A) and 36(1B) expand the Minister’s ability to disclose information obtained in the exercise of his functions under the SAFL. 

Under the amended provisions, the Minister may now disclose such information to any person, provided he considers the disclosure appropriate in the circumstances. This represents a broadening of the previous information sharing framework and is designed to facilitate cooperation with both domestic and international counterparts, including regulators, law enforcement agencies and other relevant bodies. 

The changes are likely to support more effective enforcement of sanctions and improve coordination across jurisdictions, reflecting the inherently cross-border nature of sanctions compliance and investigations. 

What this means for industry 

These amendments represent a further step in strengthening Jersey’s sanctions regime. They enhance legal certainty around indirect dealings, streamline reporting obligations and enable more flexible and effective information sharing. For businesses operating in or from Jersey, the changes highlight the continued regulatory focus on sanctions compliance and the importance of maintaining up-to-date policies, procedures and training. 

Firms should consider whether their existing sanctions frameworks adequately address issues of ownership and control, whether reporting processes remain fit for purpose in light of the amended Article 32, and how they respond to requests for information from the authorities. 

How we can help 

Our Jersey Regulatory & Risk Advisory team has extensive experience advising on the Jersey sanctions regime and its practical application. Please do get in touch if you would like to discuss these updates or have any Jersey sanctions-related queries.