Guernsey Financial Services Commission issues Russia sanctions notice after UK varies listing details for Gulbakhor Ismailova

The Guernsey Financial Services Commission published a Russia sanctions notice advising that the UK Sanctions List entry for Gulbakhor Ismailova (Unique ID: RUS1327), designated under the Russia (Sanctions) (EU Exit) Regulations 2019, has been varied. The individual remains subject to an asset freeze, travel ban, trust services sanctions and director disqualification sanctions. The notice reminds businesses that UK sanctions regimes are given effect in the Bailiwick under the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations 2020 made under the Sanctions (Bailiwick of Guernsey) Law 2018. Firms must check for any accounts or other relationships with the named individual or any other designated person, and treat as frozen any funds, other assets or economic resources owned, held or controlled directly or indirectly (including derived interest and assets held for persons acting on their behalf). Any findings must be reported immediately to the States of Guernsey Policy and Resources Committee, and firms must not make funds or economic resources available to designated persons (or entities they own or control) other than where a permitted derogation applies or a licence has been issued. Where an affected relationship is identified, the Commission also expects firms to notify it and submit a Handbook Rule 12.37 report setting out, at a minimum, the relevant customer or linked transaction or asset and the nature and value of the relationship or transaction, as soon as reasonably practicable after completing statutory reporting to the Policy and Resources Committee.