Sanctions Notice - Global Anti-Corruption

Please be advised that the following persons:

• Isabel Dos Santos (Group ID: 16694)
• Dmitry Vasylovych Firtash (Group ID: 16699)
• Lada Pavlovna Firtash (Group ID: 16700)
• Denis Vladimirovich Gorbunenko (Group ID: 16701)
• Liga Lemberga (Group ID: 16698)
• Aivars Lembergs (Group ID: 16697)
• Paula Cristina Fidalgo Carvalho Das Neves Oliveira (Group ID: 16696)
• Sarju Raikundalia (Group ID: 16695)

have been added to the list of persons designated under the Global Anti-Corruption Sanctions Regulations 2021 (the UK regulations) and are subject to an asset freeze.

The individuals referred to above appear on the consolidated list, which can be found here.

The UK regulations are given effect within the Bailiwick under the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations, 2020 as amended that have been made under the Sanctions (Bailiwick of Guernsey) Law, 2018 (the Sanctions Law).

MEASURES WHICH SHOULD BE TAKEN

All businesses must check whether they maintain any accounts or otherwise have any kind of relationship with the individuals referred to above or to any other natural or legal person, entity or body designated under the legislation referred to above and must treat any funds, other assets or economic resources

• directly or indirectly belonging to, owned, held or controlled by them, whether wholly or jointly, or
• derived from any funds or economic resources directly or indirectly belonging to, owned, held or controlled by them, whether wholly or jointly, or
• belonging to individuals or entities acting on their behalf or at their direction, whether wholly or jointly

as frozen with immediate effect if this is not already the case. Businesses must report any findings to the Policy & Resources Committee immediately. They must also ensure that they have taken all other steps that may be required in order to comply with the reporting obligations at section 14 of the Sanctions Law.

Businesses must also refrain from making any funds or economic resources available directly or indirectly, wholly or jointly, to or for the benefit of

• any designated person, entity or body
• any entity directly or indirectly owned or controlled by a designated person, entity or body, whether wholly or jointly
• any individuals or entities acting on behalf or at the direction of a designated person, entity or body, whether wholly or jointly

other than in respect of transactions that come within a permitted derogation as determined by the Policy & Resources Committee, or in accordance with a licence issued by the Policy & Resources Committee, as the case may be.

The information referred to above is required by the Policy & Resources Committee in the exercise of its powers under section 15 of the Sanctions Law.

Any information or queries should be sent to [email protected] with the subject line “Global Anti-Corruption Sanctions”.

Where you have identified an affected relationship as set out above, please also inform the Guernsey Financial Services Commission via email to [email protected] providing short form information on the nature of the sanction connection and the measures you have taken or intend to take.

Handbook Rule 12.37, requires that, where you have identified an affected relationship as set out above, the firm must provide a report to the Commission which sets out, as a minimum: a) the name of the customer, beneficial owner, key principal or the transaction and/or asset linked to a sanctioned/designated person; and b) the nature of the business relationship or occasional transaction, including the transaction and/or asset value.

This report should be provided to the Commission as soon as reasonably practicable after the firm has met the statutory reporting requirements to the States of Guernsey Policy and Resources Committee.

Further information on the effect of asset freezes and related issues including licences is available on the States of Guernsey website at http://www.gov.gg/sanctions.