Guernsey Financial Services Commission issues domestic counter-terrorism sanctions notice on Kieran James Gallagher and the New Irish Republican Army

The Guernsey Financial Services Commission published a domestic counter-terrorism sanctions notice advising that Kieran James Gallagher (Unique ID: CTD009) and the New Irish Republican Army (Unique ID: CTD0010) have been designated under the UK Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 and are subject to a full asset freeze as applied in the Bailiwick of Guernsey. Firms are required to check whether they hold accounts for, or otherwise have relationships with, the designated individuals/entities (or other designated persons under the relevant legislation) and to treat relevant funds, other assets and economic resources as frozen with immediate effect where not already frozen, including assets owned or controlled directly or indirectly and assets linked to persons acting on their behalf or at their direction. Any findings must be reported immediately to the States of Guernsey Policy & Resources Committee, and firms must meet the reporting obligations under section 14 of the Sanctions (Bailiwick of Guernsey) Law, 2018. The notice also reminds firms to refrain from making funds or economic resources available, directly or indirectly, to designated persons or their owned or controlled entities unless covered by a permitted derogation or a licence, and to inform the Commission where an affected relationship is identified, including submitting a Handbook Rule 12.37 report setting out at least the relevant customer/party details, the nature of the relationship or transaction and the related value, as soon as reasonably practicable after statutory reporting to the Policy & Resources Committee.