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Circumstances in Afghanistan continue to change following Taliban takeover in August. There remains uncertainty over the form of a future government, but the Taliban has a number of sanctioned individuals in positions of authority within the organisation. External Relations again reminds businesses that UN sanctions are already in place against individuals and entities associated with the Taliban.
Given this heightened risk context, those engaging or considering engaging in any financial activity in relation to Afghanistan should:
consider conducting enhanced due diligence including in respect of entities that may be owned or controlled by designated persons
check the UK consolidated list and consider seeking independent legal advice before undertaking any activity
Please note that members of the Taliban are listed under the UN Afghanistan regime. Individuals and entities with links to the Afghan Taliban are also listed under the ISIL (Da'esh) and Al-Qaida sanctions regime. Both these regimes are implemented in Jersey under the Sanctions and Asset-Freezing (Jersey) Law 2019 and the Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021.
The Financial Action Task Force (FATF) has issued a public statement calling on all jurisdictions' competent authorities to provide advice and facilitate information sharing with their private sectors on assessing and mitigating any emerging ML/TF risks identified in Afghanistan.
The UK Office of Financial Sanctions Implementation (OFSI) has also updated its charity sector guidance, to help support the delivery of humanitarian aid to Afghanistan.
Guidance on sanctions can be found on both the Government of Jersey and Jersey Financial Services Commission websites. The JFSC also publishes regime specific guidance, including for the Afghanistan and ISIL (Da'esh) and Al-Qaida regimes.
If you have any questions about this notification, please contact sanctions@gov.je
