Guernsey Financial Services Commission issues Russia sanctions notice listing 39 UK designations and requiring immediate asset freezes and reporting

The Guernsey Financial Services Commission has published a Russia sanctions notice alerting firms that 34 entities and five individuals have been designated under the United Kingdom’s Russia (Sanctions) (EU Exit) Regulations 2019, as implemented in the Bailiwick of Guernsey. The listed persons are subject to an asset freeze and trust service sanctions and appear on the UK consolidated list. Businesses must check whether they hold accounts or have any relationship with the designated persons and must treat relevant funds, assets and economic resources as frozen with immediate effect where not already frozen, including assets held or controlled directly or indirectly, derived property such as interest and dividends, and assets linked to persons acting on behalf of designated parties. Any findings must be reported immediately to the States of Guernsey Policy & Resources Committee and firms must comply with reporting obligations under section 14 of the Sanctions (Bailiwick of Guernsey) Law, 2018; they must also refrain from making funds or economic resources available to designated persons or related owned or controlled entities unless a permitted derogation applies or a licence has been issued by the Policy & Resources Committee. Where an affected relationship is identified, Handbook Rule 12.37 requires firms to report to the Commission as soon as reasonably practicable after making the statutory report, including at minimum the name of the relevant customer, beneficial owner, key principal or linked transaction or asset, and the nature and value of the relationship or transaction.