The Guernsey Financial Services Commission published a sanctions notice following the United Nations Security Council Committee’s addition of Hamidah NABAGALA (QDi.439) to the ISIL (Da’esh) and Al‑Qaida sanctions list and the update of the UN Consolidated List. The notice highlights that the update is automatically effective in the UK under the ISIL (Da’esh) and Al‑Qaida (United Nations Sanctions) (EU Exit) Regulations 2019 and is given effect in the Bailiwick of Guernsey through the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations 2020 made under the Sanctions (Bailiwick of Guernsey) Law 2018. All businesses are required to check whether they maintain any accounts or other relationships with the newly listed person or any other person or entity designated under the relevant legislation, and to treat as frozen with immediate effect any funds, assets or economic resources directly or indirectly owned, held or controlled by designated persons (including jointly), including derived property such as interest and dividends, and assets held by 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 in section 14 of the Sanctions Law; businesses must also refrain from making funds or economic resources available to designated persons (or entities they own or control, or persons acting on their behalf) 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 submit a report under Handbook Rule 12.37 containing at least the relevant customer or transaction/asset details and the nature of the relationship or transaction, including values, as soon as reasonably practicable after meeting the statutory reporting requirements to the Policy & Resources Committee.

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