Guernsey Financial Services Commission notifies firms of UK sanctions list variation for Mikhail Fridman

The Guernsey Financial Services Commission has alerted firms that the UK Sanctions List entry for Mikhail Fridman has been varied under The Russia Sanctions EU Exit Regulations 2019. Fridman remains designated and is still subject to an asset freeze, travel ban, trust services sanctions, a director disqualification sanction and a transport sanction. The Commission noted that the UK regime applies in the Bailiwick through Guernsey's sanctions implementation framework. Businesses must check whether they hold accounts for, or otherwise have any relationship with, Fridman or any other designated person, entity or body. Any funds, assets or economic resources belonging to, owned, held or controlled by such persons, including indirectly or through persons acting on their behalf, must be treated as frozen immediately if that has not already been done. Firms must not make funds or economic resources available to designated persons or to entities they own or control, except where a permitted derogation applies or a licence has been issued by the Policy and Resources Committee. Where a relevant relationship is identified, firms must report their findings immediately to the Policy and Resources Committee and meet the reporting obligations under section 14 of the Sanctions Law. They must also notify the Guernsey Financial Services Commission and, under Handbook Rule 12.37, provide a report setting out at least the sanctioned-linked customer, beneficial owner, key principal, transaction or asset, and the nature and value of the business relationship or occasional transaction, as soon as reasonably practicable after the statutory report has been made.