Guernsey Financial Services Commission lists UK cyber sanctions designees now subject to an asset freeze in Guernsey

The Guernsey Financial Services Commission issued a cyber sanctions notice advising that 18 individuals and the 161st Specialist Training Centre (TsPS) have been designated under the UK’s Cyber (Sanctions) (EU Exit) Regulations 2020 and are subject to an asset freeze in the Bailiwick of Guernsey. The UK cyber sanctions regime is applied locally via the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations 2020 made under the Sanctions (Bailiwick of Guernsey) Law 2018. Businesses are required to check whether they hold accounts for, or otherwise have relationships with, the listed designees or any other person designated under the relevant legislation, and to freeze with immediate effect any funds, other assets or economic resources belonging to, owned, held or controlled by them directly or indirectly, including jointly held assets and derived property such as interest and dividends. Any findings must be reported immediately to the States of Guernsey Policy & Resources Committee, and firms must comply with the reporting requirements in section 14 of the Sanctions Law, while also ensuring they do not make funds or economic resources available to or for the benefit of designated persons (including owned or controlled entities and 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 must also notify the Commission and provide a report under Handbook Rule 12.37, as soon as reasonably practicable after meeting their statutory reporting obligations.