Guernsey Financial Services Commission alerts firms to four new UK Sudan designations and asset freeze obligations

The Guernsey Financial Services Commission issued a sanctions notice advising that four individuals have been designated under the United Kingdom’s Republic of Sudan (Sanctions) (EU Exit) Regulations 2019 and are now subject to an asset freeze in the Bailiwick of Guernsey under the local regime that implements UK sanctions. The designated individuals are Abdul Rahim Hamdan DAGLO (OFSI Group ID 17257, Unique ID SUD0022), Al-Fateh Abdullah IDRIS (17258, SUD0023), Gedo Hamdan AHMED (17259, SUD0024) and Tijani Ibrahim Moussa MOHAMED (17260, SUD0025). Businesses must check whether they hold accounts for, or have any relationship with, the designated persons (or others designated under the relevant legislation) and must freeze without delay any funds, assets or economic resources belonging to, owned, held or controlled by them, including derived interest and dividends and assets held by persons acting on their behalf or at their direction. Any findings must be reported immediately to the States of Guernsey Policy & Resources Committee and firms must comply with the reporting obligations in section 14 of the Sanctions (Bailiwick of Guernsey) Law, 2018; firms must also not make funds or economic resources available to designated persons, their controlled entities, or those acting on their behalf, except where a permitted derogation applies or a licence has been issued by the Policy & Resources Committee. Where an affected relationship is identified, firms should also inform the Commission, and Handbook Rule 12.37 requires a report to the Commission (at minimum, identifying the customer/beneficial owner/key principal or linked transaction/asset, and describing the relationship or transaction including value) as soon as reasonably practicable after the statutory report has been made to the Policy & Resources Committee.