Guernsey Financial Services Commission issues Haiti sanctions notice confirming two new UK designations and asset freeze requirements

The Guernsey Financial Services Commission issued a sanctions notice advising that two individuals have been designated under the UK Haiti (Sanctions) Regulations 2020 and are now subject to an asset freeze in the Bailiwick of Guernsey through Guernsey’s implementation of UK sanctions regimes. The notice identifies Dimitri Herard (Unique ID: HAI0012) and Kempes Sanon (Unique ID: HAI0013) as designated persons on the UK sanctions list. Businesses are instructed to familiarise themselves with the restrictions, check for any accounts or other relationships connected to the designated persons, and treat relevant funds, other assets and economic resources as frozen with immediate effect if not already frozen, including assets owned or controlled directly or indirectly, jointly or wholly, and assets held for persons acting on their behalf or at their direction. Firms must also refrain from making funds or economic resources available to or for the benefit of designated persons or entities they own or control, except where a permitted derogation applies or a licence has been issued by the States of Guernsey Policy & Resources Committee. Any findings must be reported immediately to the Policy & Resources Committee in line with statutory reporting requirements under the Sanctions (Bailiwick of Guernsey) Law, 2018, and firms should also notify the Commission where an affected relationship is identified. The notice highlights Handbook Rule 12.37, which requires a report to the Commission containing, at a minimum, the relevant customer or transaction details and the nature and value of the relationship or transaction, provided as soon as reasonably practicable after statutory reporting to the Policy & Resources Committee.