On 14 April, Stephenson Hardwood published an article explaining that, from 10 May, EU sanctions ban TCSP from providing trustee or other fiduciary services to trusts and similar structures connected with Russian nationals.  This, it says, means that all EU TCSP are required to comply with the new sanctions by divesting themselves of any and all affected Russian-related business by 10 May.  This includes providing administration services to trusts and similar structures connected with Russian nationals.  It warns that the sanctions are widely drawn and have the potential to affect all TCSP worldwide, not just those who are located within the EU. his is because the sanctions apply to any EU person, including an EU national working for a non-EU TCSP or a non-EU TCSP conducting business wholly or in part within the EU.

Any modest contributions for my time and ongoing expenses are welcomed!  I have a page where you can do so, and where one-off contributions start as low as $3, at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

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