The Guernsey Financial Services Commission has issued a notice that ALT CAPITAL PTE LTD, Vladislav Gromov and Narmina Dadashova have been designated under the United Kingdom’s Russia (Sanctions) (EU Exit) Regulations 2019, which apply in the Bailiwick of Guernsey. The designations carry asset freezes, director disqualification sanctions, travel bans and trust services sanctions. Businesses must check for affected relationships, freeze relevant assets immediately and report their findings.
The checks must cover relationships with these and other parties designated under the legislation. Freezing obligations extend to funds, assets and economic resources owned, held or controlled directly or indirectly, wholly or jointly, by designated parties, including derived income and assets belonging to those acting on their behalf or at their direction. Businesses must not make funds or economic resources available to or for the benefit of designated parties, entities they own or control, or those acting on their behalf or at their direction, unless covered by a permitted derogation or a licence from the Policy & Resources Committee.
Findings must be reported immediately to the Policy & Resources Committee, alongside compliance with the statutory reporting obligations. Firms identifying an affected relationship must also report to the Commission as soon as reasonably practicable after meeting those statutory requirements. The report must identify the customer, beneficial owner, key principal, transaction or asset linked to a designated person and describe the relationship or transaction, including its transaction or asset value. Firms should also provide details of the sanctions connection and measures taken or planned.