Guernsey Financial Services Commission issues Russia sanctions notice following UK designation of Aeza Group LLC

The Guernsey Financial Services Commission published a sanctions notice advising that Aeza Group LLC has been designated under the United Kingdom’s Russia (Sanctions) (EU Exit) Regulations 2019 and is now subject to sanctions in the Bailiwick of Guernsey. The notice notes that the UK regulations are implemented in Guernsey via the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations 2020 made under the Sanctions (Bailiwick of Guernsey) Law, 2018. It instructs all businesses to check for any accounts or other relationships with the designated entity (and any other designated persons) and to treat relevant funds, assets and economic resources as frozen with immediate effect, including assets held or controlled directly or indirectly and assets linked to persons acting on behalf of, or at the direction of, a designated person. Firms must report findings to the States of Guernsey Policy & Resources Committee immediately and comply with the reporting obligations under section 14 of the Sanctions Law, and must not make funds or economic resources available to designated persons (or entities they own or control) except where a permitted derogation applies or a licence has been issued by the Policy & Resources Committee. Where an affected relationship is identified, firms are also expected to notify the Commission and, under Handbook Rule 12.37, submit a report setting out at least the relevant customer/beneficial owner/key principal or linked transaction/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.