Guernsey Financial Services Commission issues Russia sanctions notice for PJSC Surgutneftegas and Gazprom Neft and sets immediate asset freeze and reporting expectations

The Guernsey Financial Services Commission published a Russia sanctions notice advising that PJSC SURGUTNEFTEGAS (Unique ID: RUS2382) and GAZPROM NEFT (Unique ID: RUS2383) have been designated under the United Kingdom’s Russia (Sanctions) (EU Exit) Regulations 2019, as given effect in the Bailiwick of Guernsey. Businesses are expected to identify any relevant relationships and ensure applicable funds, assets and economic resources are treated as frozen with immediate effect. Firms must check whether they maintain accounts or other relationships with any designated person or entity, including those directly or indirectly owned or controlled by a designated party or acting on their behalf. Any funds or economic resources belonging to, owned, held or controlled by a designated party, including derived interests such as dividends, must be frozen and findings reported to the States of Guernsey Policy & Resources Committee in line with reporting obligations under section 14 of the Sanctions (Bailiwick of Guernsey) Law 2018. The notice also reiterates the prohibition on making funds or economic resources available to designated persons or connected parties, except where a permitted derogation applies or a licence has been issued by the Policy & Resources Committee, and it requires firms to notify the Commission where an affected relationship is identified and to submit a Handbook Rule 12.37 report covering, at a minimum, the relevant customer or linked transaction or asset, the nature of the relationship or transaction, and the value, as soon as reasonably practicable after statutory reporting.