Guernsey Financial Services Commission alerts firms to UK sanctions list variation for OJSC Keremet Bank

The Guernsey Financial Services Commission issued a Russia sanctions notice advising that the UK Sanctions List entry for OJSC Keremet Bank (Unique ID: RUS2479), designated under The Russia (Sanctions) (EU Exit) Regulations 2019, has been varied. The bank remains subject to an asset freeze and related restrictions as implemented in the Bailiwick of Guernsey through the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations, 2020 under the Sanctions (Bailiwick of Guernsey) Law, 2018. Firms must check whether they hold accounts for, or otherwise have a relationship with, the designated entity or any other designated person and must treat relevant funds, assets and economic resources as frozen with immediate effect where this is not already the case. Businesses must also refrain from making funds or economic resources available, directly or indirectly, to or for the benefit of designated persons (including owned or controlled entities and those acting on their behalf), except where a permitted derogation applies or a licence has been issued by the Policy & Resources Committee; any findings must be reported to the Policy & Resources Committee and firms must comply with section 14 reporting obligations. Where an affected relationship is identified, firms should also inform the Commission and provide a report in line with Handbook Rule 12.37, including (as a minimum) the name of the customer, beneficial owner, key principal or linked transaction and or asset, and the nature of the relationship or transaction including the transaction and or asset value, as soon as reasonably practicable after statutory reporting to the Policy & Resources Committee.