Guernsey Financial Services Commission alerts firms to new UK Global Irregular Migration sanctions designations and reporting requirements

The Guernsey Financial Services Commission (GFSC) issued a sanctions notice advising that the UK has introduced a new sanctions regime under the Global Irregular Migration and Trafficking in Persons (Sanctions) Regulations 2025 and has designated a number of individuals and entities. The GFSC expects Bailiwick implementing legislation to be introduced shortly and, in the interim, instructs businesses to check for any accounts or other relationships with the designated persons and report any findings to the States of Guernsey Policy & Resources Committee. The designations listed in the notice include several criminal groups, a corporate entity and multiple named individuals, all of whom appear on the UK consolidated list. The GFSC also warns that breaching the UK immigration legislation underpinning the regime is currently an offence in the Bailiwick, meaning dealings with funds belonging to a person designated under the regime may involve committing an immigration offence. Where an affected relationship is identified, firms are asked to notify the GFSC and to provide a report under Handbook Rule 12.37 setting out at least the relevant customer or connected party or linked transaction and/or asset, the nature of the relationship or occasional transaction, and the transaction and/or asset value, as soon as reasonably practicable after completing the statutory reporting to the Policy & Resources Committee.