Guernsey Financial Services Commission flags UN Iraq sanctions list amendment for Bashar Sabawi Ibrahim Hasan Al-Tikriti

The Guernsey Financial Services Commission issued a sanctions notice following an amendment by the United Nations Security Council Committee established under Resolution 1518 (2003) on Iraq to the UN Consolidated List relating to Bashar Sabawi Ibrahim Hasan Al-Tikriti (IQi.085). The notice reminds firms that changes to the UN Consolidated List are automatically effective in the UK under the Iraq (Sanctions) (EU Exit) Regulations 2019 and are given effect in the Bailiwick of Guernsey through local implementing regulations made under the Sanctions (Bailiwick of Guernsey) Law 2018. Businesses must check whether they maintain accounts or have any relationship with the individual named in the notice or any other designated person or entity, and must treat relevant funds, assets and economic resources as frozen with immediate effect where not already frozen. Any findings must be reported immediately to the States of Guernsey Policy & Resources Committee, alongside compliance with reporting obligations in section 14 of the Sanctions Law, and firms must refrain from making funds or economic resources available to designated persons (or entities they own or control, or persons acting on their behalf) other than 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 inform the Commission and provide a report under Handbook Rule 12.37 as soon as reasonably practicable after the statutory report has been made to the Policy & Resources Committee, including at least the relevant customer or transaction identifiers, the nature of the relationship or transaction, and the transaction and or asset value.