The UK Government has varied the designations of sanctioned entities and individuals, making them subject to Director Disqualification Sanctions and UK Director Disqualification Sanctions.
On 9 April, the UK Government varied the designation of thousands of individuals and entities sanctioned under 28 UK autonomous and mixed sanctions regimes, meaning they are now subject to Director Disqualification Sanctions.
Section 3A of the Sanctions and Anti-Money Laundering Act 2018 (SAMLA 2018) allows the imposition of director disqualification sanctions. Individuals to these are prohibited from:
- acting as a director of a UK company
- acting as a director of a foreign company that has sufficient connection to the UK, even if it is not registered here (for example, if it carries out business or has assets here)
- taking part in, or being concerned, in the promotion, formation or management of a company
However, these prohibitions are subject to exceptions and licences. An Insolvency Service Licence may be obtained to allow the carrying out of otherwise prohibited acts. A licence will only be issued for a defined period and may contain conditions that the licence holder must meet.
Jersey Director Disqualification Sanctions
The UK’s variation of designation, introduced on 9 April, became effective immediately in Jersey by virtue of The Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021 (‘the Sanctions Order’), made under the Sanctions and Asset-Freezing (Jersey) Law 2019 (‘SAFL’).
Earlier in 2025, Jersey adopted the Sanctions and Asset-Freezing (Implementation of External Sanctions – Director Disqualification) (Jersey) Amendment Order 2025, which prohibits a person subject to director disqualification sanctions from:
(a) acting as a as a director of a company, or directly or indirectly taking part in or being concerned with the promotion, formation or management of a company; or
(b) acting as a manager of a limited liability company, or directly or indirectly taking part in or being concerned with the promotion, formation or management of a limited liability company,
unless a licence or exception is in place.
On 27 February 2025, the Minister for External Relations issued the Jersey General Licence (Director Disqualification) INT/JSY/2025/1 (the ‘Jersey General Licence’), which authorises:
- acting company directors or managers of limited liability companies, designated for the purposes of directors’ disqualification sanctions, to undertake activities required in connection with the discharge of, or compliance with, Jersey or UK statutory or regulatory requirements; and
- actions taken strictly in relation to the resignation of a designated person as a director of a company or as a manager of a limited liability company.
The Jersey General Licence will expire on 31 December 2025, and anyone relying on it must report to the Minister within 7 working days of having done so, providing details of any actions taken or transactions made.
If you would like to find out more about the Director Disqualification Sanctions or apply for a licence that would allow you to continue acting as a director of UK company, please contact us for legal advice. Our lawyers have significant experience advising on sanctions matters and can assist with a licence application.
Updated: 14 April 2025
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