Guernsey Financial Services Commission amends Russia sanctions entry for Tinkoff Bank while maintaining asset freeze

The Guernsey Financial Services Commission has issued a Russia sanctions notice advising that the details for Tinkoff Bank (Unique ID: RUS1859), designated under the United Kingdom’s Russia (Sanctions) (EU Exit) Regulations 2019, have been amended, while the bank remains subject to an asset freeze. The notice highlights that the UK regime is given effect in the Bailiwick of Guernsey through local implementation regulations made under the Sanctions (Bailiwick of Guernsey) Law, 2018, and that designated persons and entities appear on the UK consolidated list. Businesses are required to check for any accounts or relationships with the designated entity or other designated persons or entities and, where relevant, ensure funds, other assets and economic resources are treated as frozen with immediate effect. Any findings must be reported immediately to the States of Guernsey Policy & Resources Committee, and firms must not make funds or economic resources available directly or indirectly to designated persons, their owned or controlled entities, or those acting on their behalf, except where a permitted derogation applies or a licence has been issued. Where an affected relationship is identified, firms should also notify the Commission and provide a report under Handbook Rule 12.37 setting out at least the relevant customer or asset details, the nature of the relationship or transaction, and the transaction or asset value, as soon as reasonably practicable after meeting the statutory reporting requirements to the Policy & Resources Committee.