Sanctions Notice - Global Anti-Corruption Sanctions

Please be advised that the Bailiwick has implemented a new sanctions regime; the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) (Amendment - Global Anti-Corruption) Regulations, 2021 implement the Global Anti-Corruption Sanctions Regulations 2021 put in place by the UK to prevent and combat serious corruption.

These regulations have replaced the Misappropriation (Sanctions) (EU Exit) Regulations 2020, given effect within the Bailiwick under the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations, 2020 (the 2020 regulations), concerning misappropriation of State funds from any country outside the UK.

Changes are being made to the States of Guernsey website’s sanctions pages to reflect the above.

The following 22 individuals have been added to the Global Anti-Corruption regime:

Russia

1. Artem KUZNETSOV
2. Pavel KARPOV
3. Stanislav GORDIEVSKY
4. Olga STEPANOVA
5. Vladlen STEPANOV
6. Yelena KHIMINA
7. Andrey PAVLOV
8. Aleksey SHESHENYA
9. Gennady PLASKIN
10. Vyacheslav KHLEBNIKOV
11. Viktor MARKELOV
12. Dmitry KLYUEV
13. Oleg URZHUMTSEV
14. Yulia MAYOROVA

South Sudan

15. Ashraf Seed Ahmed Hussein Ali (AL-CARDINAL)

South Africa

16. Ajay GUPTA
17. Atul GUPTA
18. Rajesh “Tony” GUPTA
19. Salim ESSA

Latin America (Honduras, Niguragua and Guatalama)

20. Oscar Ramón NÁJERA
21. José Francisco LÓPEZ CENTENO
22. Felipe ALEJOS LORENZANA 

These individuals are on the consolidated list, which can be found here, and are subject to an asset freeze.

MEASURES WHICH SHOULD BE TAKEN

All businesses must check whether they maintain any accounts or otherwise have any kind of relationship with the persons 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”.

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