The Guernsey Financial Services Commission has published a Russia sanctions notice advising that additional individuals and entities have been designated under the Russia (Sanctions) (EU Exit) Regulations 2019, with the UK regime given effect in the Bailiwick under Guernsey’s implementing regulations made under the Sanctions (Bailiwick of Guernsey) Law, 2018. The designated persons are subject to an asset freeze and trust services sanctions and appear on the UK consolidated list. All businesses must check whether they maintain accounts or have any other relationship with any of the listed designated persons, or any other persons designated under the relevant legislation, and must freeze with immediate effect any funds, assets or economic resources directly or indirectly belonging to, owned, held or controlled by them, including where held jointly or through persons acting on their behalf. Firms must report any findings immediately to the States of Guernsey Policy & Resources Committee, comply with the statutory reporting obligations in section 14 of the Sanctions Law, and refrain from making funds or economic resources available to designated persons or their 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 a report to the Commission as soon as reasonably practicable after the statutory reporting to the Policy & Resources Committee, including at least the relevant customer, beneficial owner, key principal, transaction or asset linked to the sanctioned person, and the nature and value of the relationship or occasional transaction.

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