Guernsey Financial Services Commission alerts firms to 43 Russia sanctions designations and immediate asset freeze reporting duties

The Guernsey Financial Services Commission issued a notice that 43 individuals and entities have been designated under the United Kingdom Russia sanctions regime, which has effect in the Bailiwick under Guernsey’s sanctions implementation framework. Firms must check whether they hold accounts or maintain any other relationship with those designated persons or with any other person or entity designated under the same legislation, and must freeze with immediate effect any funds, assets or economic resources that are directly or indirectly owned, held or controlled by them, including assets held jointly and assets derived from them. The notice also requires businesses to refrain from making funds or economic resources available, directly or indirectly, to designated persons, entities they own or control, or persons acting on their behalf or at their direction, unless a permitted derogation applies or a licence has been issued by the Policy & Resources Committee. Any findings must be reported immediately to the Policy & Resources Committee in line with section 14 of the Sanctions Law. Where an affected relationship is identified, firms must also inform the Guernsey Financial Services Commission and, under Handbook Rule 12.37, provide a report setting out at least the relevant customer, beneficial owner, key principal, transaction or asset linked to the sanctioned person and the nature and value of the business relationship or occasional transaction. That report should be submitted to the Commission as soon as reasonably practicable after the statutory report to the Policy & Resources Committee.