Sanctions Notice - Russia

Please be advised that the Russia (Sanctions) (EU Exit) Regulations 2019 (the UK regulations) have been amended by the Russia (Sanctions) (EU Exit) (Amendment) (No.3) Regulations 2023 (the Amending regulations).

The UK 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 changes made to the UK regulations by the Amending regulations are automatically effective within the Bailiwick.

The Amending regulations are available here: The Russia (Sanctions) (EU Exit) (Amendment) (No. 3) Regulations 2023

The effect of the Amending regulations as implemented in the Bailiwick is to introduce a new prohibition on the provision of legal advisory services, where those services are provided in relation to activities that would be in breach of the UK Regulations if those activities were carried out in the Bailiwick or by a Bailiwick person. This is subject to a number of exemptions, including for legal advisory services provided in relation to statutory or regulatory obligations, advice about the application of the Russia regulations, work carried out before 29 September 2023 under contracts concluded before 30 June 2023, and legal services that are connected to diplomatic missions or consular posts, or are provided in relation to certain emergencies.

The Amending regulations also introduce new exemptions on the provision of professional and business services in relation to auditing services and the provision of expert evidence in legal proceedings.

MEASURES WHICH SHOULD BE TAKEN

All businesses must familiarise themselves with the new restrictions in the Amending regulations and check whether they maintain any accounts or otherwise have any kind of relationship that might be affected. If so, they must ensure that all necessary measures are in place to prevent them from breaching those restrictions or any other aspects of the UK regulations.

Businesses must report any findings to the Policy & Resources Committee immediately. This information 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 “Russia 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.

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