The Guernsey Financial Services Commission has notified firms that 13 individuals and one entity, OOO Impuls, have been designated under the United Kingdom Cyber (Sanctions) (EU Exit) Regulations 2020, which apply in the Bailiwick through Guernsey's sanctions implementation framework. The individuals are now subject to asset freeze, travel ban and director disqualification sanctions, while OOO Impuls is subject to asset freeze and director disqualification sanctions. Businesses must check whether they hold accounts or have any other relationship with the designated parties or with any other person or entity designated under the same legislation. Any funds, assets or economic resources owned, held or controlled by those parties, including assets held indirectly, derived property and assets linked to persons acting on their behalf or at their direction, must be treated as frozen immediately if not already frozen. Firms must report any findings to the Policy & Resources Committee, comply with reporting obligations under section 14 of the Sanctions Law, and must not make funds or economic resources available to designated persons, their owned or controlled entities, or persons acting for them except where a permitted derogation or licence applies. Where a firm identifies an affected relationship, Handbook Rule 12.37 also requires it to report the matter to the Commission as soon as reasonably practicable after completing the statutory report to the Policy & Resources Committee. That report must at least identify the relevant customer, beneficial owner, key principal, transaction or asset linked to a sanctioned person, and describe the business relationship or occasional transaction, including the value of the transaction or asset.

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