Sanctions Notice - Russia

Please be advised that the Policy & Resources Committee has issued the attached general licence under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations, 2019, as implemented in the Bailiwick by the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations, 2020 (the Russia Regulations).

The licence can also be found online at www.gov.gg/sanctionsmeasures.

The General Licence revokes and replaces the General Licence that was previously issued in relation to investment funds. It widens the scope of the previous General Licence by extending it to the situation where the only nexus to the Bailiwick is that an investment interest in a fund is managed by a local investment manager. Otherwise its effect is the same as that of the previous General Licence, and the revocation of that General Licence is expressly stated to be without prejudice to the lawfulness of any actions carried out in reliance on it.

MEASURES WHICH SHOULD BE TAKEN

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

In accordance with Handbook Rule 12.37, 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 via email to [email protected] 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 issues in relation to sanctions is available on the States of Guernsey website at http://www.gov.gg/sanctions.