Guernsey Financial Services Commission issues Russia sanctions notice specifying 50 ships and reiterating reporting requirements

The Guernsey Financial Services Commission (GFSC) published a Russia sanctions notice listing 50 ships specified under the UK Russia (Sanctions) (EU Exit) Regulations 2019 as given effect in the Bailiwick of Guernsey, and instructed businesses to check for any relationships linked to the named vessels and comply with applicable obligations. The notice provides each ship’s name, International Maritime Organization (IMO) number and unique ID, and reminds firms that any relevant findings must be reported immediately to the States of Guernsey Policy & Resources Committee in line with section 14 of the Sanctions (Bailiwick of Guernsey) Law, 2018. Where an affected relationship is identified, firms are also asked to notify the GFSC with brief details of the sanctions connection and actions taken or planned, and to submit a report under Handbook Rule 12.37 setting out at least the relevant customer, beneficial owner, key principal or linked transaction or asset, and the nature of the relationship or transaction including value. The report to the GFSC should be provided as soon as reasonably practicable after the firm has met its statutory reporting requirements to the Policy & Resources Committee.