The Guernsey Financial Services Commission published a sanctions notice following the UK’s creation of a Global Irregular Migration and Trafficking in Persons sanctions regime and its implementation in the Bailiwick of Guernsey via local amendment regulations. The notice reminds businesses to identify any links to designated persons and to apply asset-freeze and reporting measures with immediate effect where relevant. Businesses must check whether they hold accounts or have any relationship with any designated legal person, entity or body, with current UK designations reflected on the UK consolidated list. Any funds, assets or economic resources belonging to, owned, held or controlled by a designated person, including jointly held assets and property derived from such assets, and assets held on behalf of or at the direction of a designated person, must be treated as frozen and findings reported immediately to the States of Guernsey Policy & Resources Committee in line with the Sanctions Law. Firms must also not make funds or economic resources available, directly or indirectly, to designated persons, entities they own or control, or those 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 notify the Commission and submit a report under Handbook Rule 12.37, including at least the relevant customer or transaction/asset linked to the sanctioned party and the nature and value of the relationship or occasional transaction, as soon as reasonably practicable after meeting statutory reporting duties to the Policy & Resources Committee.

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