Guernsey Financial Services Commission highlights corrected UK cyber sanctions listing for Chosun Expo and reiterates asset-freeze reporting duties

The Guernsey Financial Services Commission issued a cyber sanctions notice advising that the UK sanctions list entry for Chosun Expo has been corrected and that the entity remains designated under the Cyber (Sanctions) (EU Exit) Regulations 2020. The UK regime is given effect in the Bailiwick under Guernsey’s implementing regulations made under the Sanctions (Bailiwick of Guernsey) Law, 2018. Businesses must check whether they have accounts or other relationships with the designated entity (or others designated under the relevant legislation) and must treat as frozen, with immediate effect, any funds, assets or economic resources directly or indirectly belonging to, owned, held or controlled by the designated party, including derived property and assets held by persons acting on its behalf or at its direction. Any findings must be reported immediately to the States of Guernsey Policy and Resources Committee and firms must comply with the section 14 reporting obligations under the Sanctions Law; firms must also not make funds or economic resources available to designated persons or entities they own or control unless covered by a permitted derogation or a licence. Where an affected relationship is identified, Handbook Rule 12.37 requires a report to the Commission, submitted as soon as reasonably practicable after the statutory report to the Policy and Resources Committee, setting out (at a minimum) the relevant customer/beneficial owner/key principal or linked transaction/asset and the nature and value of the relationship or transaction.