The Guernsey Financial Services Commission has advised firms that the UK Sanctions List entry for Mikhail Fridman has been varied under The Russia (Sanctions) (EU Exit) Regulations 2019. He remains designated and is still subject to an asset freeze, travel ban, trust services sanctions, director disqualification sanction and transport sanction. The UK measures apply in the Bailiwick of Guernsey through the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations, 2020 made under the Sanctions (Bailiwick of Guernsey) Law, 2018. Businesses must check whether they hold accounts or have any other relationship with the individual or with any other designated person, entity or body, and must freeze with immediate effect any relevant funds, assets or economic resources if this has not already been done. The obligation extends to assets directly or indirectly owned, held or controlled by designated persons, assets derived from those funds or resources, and assets of persons acting on their behalf or at their direction. Firms must report any findings immediately to the Policy & Resources Committee, meet the reporting obligations under section 14 of the Sanctions Law, and must not make funds or economic resources available to designated persons or related owned, controlled or directed parties except where a permitted derogation or licence applies. Where an affected relationship is identified, firms must also notify the Commission and, under Handbook Rule 12.37, provide a report as soon as reasonably practicable after completing the statutory report to the Policy & Resources Committee. That report must at minimum identify the customer, beneficial owner, key principal or linked transaction or asset, and describe the nature and value of the business relationship or occasional transaction.

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