Sanctions Notice - Russia

Please be advised that the UK has now designated all persons designated under the Financial Sanctions Regime for the purposes of the prohibition on providing trust services. NB: This prohibition does not apply to the provision of trust services in cases where an asset freeze is in place. 

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

The Policy & Resources Committee has issued a general licence which provides a 120 day winding down period in which to take the action necessary to exist exiting relationships.  Please note that, like the prohibition, this licence does not apply to relationships where an asset freeze is in place.

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. 

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.

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. NB: There is no requirement to make any report in respect of a matter that has previously been reported to the Policy & Resources Committee. However, anybody relying on the general licence must make reports as required by that licence.

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

Where you have identified a connection to a designated person 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.

Further information on issues in relation to sanctions is available on the States of Guernsey website at http://www.gov.gg/sanctions.   

Licensees might wish to review this blog published by the UK Government's Office of Financial Sanctions Implementation for further information.