Guernsey Financial Services Commission alerts firms to five new UK Russia sanctions designations and immediate asset-freeze requirements

The Guernsey Financial Services Commission published a Russia sanctions notice advising that five persons and entities have been designated under the United Kingdom’s Russia (Sanctions) (EU Exit) Regulations 2019 and appear on the UK consolidated list, with the UK regime given effect in the Bailiwick under Guernsey’s sanctions implementation framework. Firms are required to check whether they hold accounts for, or have any relationship with, the designated persons or any other designated natural or legal persons, entities or bodies, and to treat any relevant funds, assets or economic resources as frozen with immediate effect where not already frozen. Businesses must report any findings to the States of Guernsey Policy & Resources Committee and comply with statutory reporting obligations under section 14 of the Sanctions (Bailiwick of Guernsey) Law, 2018. They must also refrain from making funds or economic resources available (directly or indirectly) to designated persons, to entities owned or controlled by them, or to persons acting on their behalf or at their direction, 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 report under Handbook Rule 12.37 setting out at least the name of the customer, beneficial owner, key principal or linked transaction/asset, and the nature of the business relationship or occasional transaction including transaction and/or asset value, as soon as reasonably practicable after statutory reporting to the Policy & Resources Committee.