Guernsey Financial Services Commission updates Su Gwang KIM North Korea sanctions entry and reiterates asset freeze reporting duties

The Guernsey Financial Services Commission issued a sanctions notice advising that the details of the UK designation entry for Su Gwang KIM (Group ID: 13664), made under the Democratic People’s Republic of Korea (Sanctions) (EU Exit) Regulations 2019, have been amended to align with the UK Sanctions List. The individual remains subject to an asset freeze, with the UK regime implemented in the Bailiwick via the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations 2020 (as amended) under the Sanctions (Bailiwick of Guernsey) Law 2018. Businesses are required to check for any accounts or other relationships with the designated person (and others designated under the relevant legislation) and to treat all relevant funds, other assets and economic resources as frozen with immediate effect if not already frozen, then report findings to the States of Guernsey Policy & Resources Committee and meet the section 14 reporting obligations under the Sanctions Law. Firms must also not make funds or economic resources available (directly or indirectly) to designated persons, entities owned or controlled by them, or persons acting on their behalf, except where a permitted derogation applies or a licence has been issued by the Policy & Resources Committee; where an affected relationship is identified, firms should also inform the Commission and provide a Handbook Rule 12.37 report, including at least the relevant name and the nature of the relationship or transaction (and associated value), as soon as reasonably practicable after completing statutory reporting to the Policy & Resources Committee.