Guernsey Financial Services Commission issues Russia sanctions notice on 11 UK-designated persons and entities

The Guernsey Financial Services Commission published a Russia sanctions notice alerting firms that eight individuals and three organisations have been designated under the UK Russia sanctions regime, which is given effect in the Bailiwick of Guernsey through local implementation regulations. The notice sets out the immediate asset-freeze, reporting and “no funds made available” steps businesses must take where they identify a relevant relationship or assets. Firms must check whether they hold accounts for, or otherwise have relationships with, the designated persons and entities, including the All-Russian public-state movement of children and youth “Movement of the First”, the Akhmat Kadyrov Foundation and Volunteers of Victory. Any funds, other assets or economic resources directly or indirectly owned, held or controlled by the designated persons (including derived property such as interest or dividends, and assets held by persons acting on their behalf or at their direction) must be treated as frozen with immediate effect if not already frozen, and any findings must be reported to the States of Guernsey Policy & Resources Committee in line with statutory reporting obligations. Businesses must also refrain from making funds or economic resources available, directly or indirectly, to designated persons, to entities they own or control, or to 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 must also inform the Commission and submit a report under Handbook Rule 12.37 with the minimum required details, as soon as reasonably practicable after completing statutory reporting to the Policy & Resources Committee.