Sanctions Notice - Ransom Payments

​As previously advised, a number of persons associated with extremist groups in Iraq and Syria have been added to the Al-Qaida Sanctions List maintained under United Nations Security Council Resolution 1267.  A corresponding list is maintained by the European Union under Council Regulation (EC) No 881/2002, which has been implemented in the Bailiwick under the Al-Qaida (Restrictive Measures) (Guernsey) Ordinance, 2013, the Al-Qaida (Restrictive Measures) (Alderney) Ordinance, 2013 and the Al-Qaida (Restrictive Measures) (Sark) Ordinance, 2013.

Article 17 of United Nations Security Council Resolution 2170, issued on 15 August 2014, confirms that the financial restrictions imposed in relation to listed persons apply to the payment of ransoms to individuals, groups, undertakings or entities on the Al-Qaida Sanctions List, regardless of how or by whom the ransom is paid.

Businesses are advised to exercise extreme caution in respect of any transactions that might involve payments of this kind.  Any relevant information should be reported to the Policy Council.  Businesses are also reminded that a request to carry out such a transaction may give rise to knowledge, suspicion or reasonable grounds for knowledge or suspicion that another person is engaged in terrorist financing, in which case a disclosure should be made to the Financial Intelligence Service in the form and manner prescribed by the Terrorism and Crime (Bailiwick of Guernsey) Regulations 2007, as amended.