Guernsey Financial Services Commission issues Russia sanctions notice listing newly specified ships and reiterating reporting obligations

The Guernsey Financial Services Commission published a Russia sanctions notice identifying ships specified under the Russia (Sanctions) (EU Exit) Regulations 2019, as given effect in the Bailiwick of Guernsey through local implementing regulations made under the Sanctions (Bailiwick of Guernsey) Law 2018. Firms are expected to check whether they have any business relationships linked to the listed vessels and to report any relevant findings in line with statutory and regulatory requirements. The notice lists each ship by name and Unique ID, with further vessel details (including IMO numbers) available through the Unique ID references. Businesses must report any identified links to the States of Guernsey Policy & Resources Committee immediately and take any other steps required to comply with reporting obligations under section 14 of the Sanctions Law, with information requested for the Committee’s use of its powers under section 15. Where an affected relationship is identified, firms must also notify the Commission, and Handbook Rule 12.37 requires a report to the Commission setting out, at minimum, the relevant customer/beneficial owner/key principal or the linked transaction and/or asset, and the nature of the relationship or occasional transaction including the transaction and/or asset value. The Rule 12.37 report should be provided to the Commission as soon as reasonably practicable after the firm has met the statutory reporting requirements to the Policy & Resources Committee.