We note the decisions of the Judicial Committee of the Privy Council in this long running matter concerning former Providence directors, copies of which can be found here and here. The matter now reverts to the Royal Court for its consideration of the guidance issued to it by the Court of Appeal in its judgement of 3 October 2025. 

Please be advised that the following have been added to the list of individuals and entities who are currently designated under the Global Human Rights Sanctions Regulations 2020 (the UK regulations):

The persons/entities referred to above appear on the UK Sanctions list, which can be found here.

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).

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
• that comprise interest, dividends or other forms of property derived from any funds or economic resources that belong to them or are owned, held or controlled by them, whether directly or indirectly and 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 sanctions@gov.gg with the subject line “Global Human Rights Sanctions”.

Where you have identified an affected relationship as set out above, please also inform the Guernsey Financial Services Commission via email to amlcft@gfsc.gg providing short form information on the nature of the sanction connection and the measures you have taken or intend to take.

Handbook Rule 12.37, requires that, 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 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 the effect of asset freezes and related issues including licences is available on the States of Guernsey website at http://www.gov.gg/sanctions.

Please be advised that details in respect of the following individuals and entities, which are designated under The Russia (Sanctions) (EU Exit) Regulations 2019, have been varied on the UK Sanctions List.

• Ahmed KERIMOV (Unique ID: RUS2529)
• Talat SAFAROV (Unique ID: RUS2531)
• Anar MADATLI (Unique ID: RUS2532)

The above individuals are still subject to Asset freeze, Travel Ban, Trust Services Sanctions, Director Disqualification Sanction and Transport Sanction and appear on the UK sanctions list, which can be found here.

• 2RIVERS PTE LTD (Unique ID: RUS2380)
• 2RIVERS DMCC (Unique ID: RUS2381)

The above entities are still subject to Asset freeze, Trust Services Sanctions, Director Disqualification Sanction and Transport Sanction and appear on the UK sanctions list.

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).

MEASURES WHICH SHOULD BE TAKEN

All businesses must check whether they maintain any accounts or otherwise have any kind of relationship with the individuals/entities 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
• that comprise interest, dividends or other forms of property derived from any funds or economic resources that belong to them or are owned, held or controlled by them, whether directly or indirectly and 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 sanctions@gov.gg 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 amlcft@gfsc.gg providing short form information on the nature of the sanction connection and the measures you have taken or intend to take.

Handbook Rule 12.37, requires that, 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 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 the effect of asset freezes and related issues including licences is available on the States of Guernsey website at http://www.gov.gg/sanctions.

Please be advised that details in respect of the following individual:

• Liran COHEN (Unique ID: RUS3607)

who is designated under The Russia (Sanctions) (EU Exit) Regulations 2019, have been varied on the UK Sanctions List.

The above individual is still subject to Asset freeze, Travel Ban, Trust Services Sanctions, Director Disqualification Sanction and appears on the UK sanctions list, which can be found here.

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).

MEASURES WHICH SHOULD BE TAKEN

All businesses must check whether they maintain any accounts or otherwise have any kind of relationship with the individual 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
• that comprise interest, dividends or other forms of property derived from any funds or economic resources that belong to them or are owned, held or controlled by them, whether directly or indirectly and 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 sanctions@gov.gg 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 amlcft@gfsc.gg providing short form information on the nature of the sanction connection and the measures you have taken or intend to take.

Handbook Rule 12.37, requires that, 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 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 the effect of asset freezes and related issues including licences is available on the States of Guernsey website at http://www.gov.gg/sanctions.

Please be advised that the following specification has been revoked from the UK Russia financial sanctions regime. This entity is no longer subject to UK sanctions.

• Limited Liability Company responsibility of “RBRU Specialized Depository” (Unique ID: RUS2682)

The UK sanctions list has been updated and can be found here.

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).

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.

Guernsey Funds  

The total net asset value of Guernsey funds at the end of the quarter was £272.6 billion, a decrease over the quarter of £0.2 billion (-0.1%). Over the past year, total net asset values have decreased by £6.0 billion (-2.2%). 

Closed-ended Funds

Within these totals, Guernsey closed-ended funds increased over the quarter by £4.5 billion (+2.0%) to just under £229.0 billion.  This represents a decrease of £3.8 billion (-1.6%) in the past year.

Open-ended Funds  

The Guernsey-domiciled open-ended sector decreased over the quarter by £4.8 billion (-9.9%) to £43.6 billion.  This represents a decrease of £2.3 billion (-5.0%) in the past year.

Guernsey Sustainable Funds

Within these totals for Guernsey funds, Guernsey Sustainable Funds held a total net asset value of £4.4 billion at the end of the quarter.

The statistics are available here.

Enquiries to: Andrew Dempster, Deputy Director, Investment, Fiduciary and Pension Division

Tel: (01481) 712706   International Dialling Code: +44 1481   Email: adempster@gfsc.gg

The Guernsey Financial Services Commission has today published its 2025 Annual Report and Financial Statements, highlighting a year of regulatory delivery, policy reform and investment in technology to support innovation and growth in the Bailiwick’s financial services sector.

The report shows how the Commission worked through 2025 to maintain a credible and internationally respected regulatory framework, while helping ensure Guernsey remains a stable, competitive and forward-looking jurisdiction.

It also underlines the importance of engagement with industry, government and international partners, and the Commission’s focus on regulation that is proportionate, effective and designed to sustain growth.

Driving innovation and digital delivery

A major development in 2025 was the completion of the Applications & Authorisations Portal, giving industry a more user-friendly way to submit applications and communicate with the Commission. By the end of the year, more than 220 applications had been received through the portal.

The Commission also launched the Digital Finance Initiative working with industry through the Digital Forum to further develop Guernsey as a destination of choice for digital finance.

Policy and regulatory developments

Policy work during the year focused on supporting competitiveness and resilience across the jurisdiction. In additional to the DFI policy work, key developments included:

• Streamlining and enhancing the Private Investment Fund regime;
• Updating the Prospectus Rules and Guidance;
• Issuing feedback on sustainability reporting; and
• Introducing a regulatory framework for equity release products.

Together, these developments reflect the Commission’s focus on supporting innovation and growth while maintaining high standards and avoiding unnecessary burdens on well-managed firms.

Stable sector with ongoing opportunities

Against a backdrop of global uncertainty, the report notes that Guernsey’s financial services sector remained stable, supported by continued demand for investment funds and other investment and insurance entities.

The Commission also highlights the opportunities created by technological change, including AI, while recognising the need to manage increasing risks in areas such as cyber security and geo-political events.

Director General William Mason said: “In 2025, the Commission, having successfully concluded the MONEYVAL evaluation with the strong MONEYVAL report published in February which secured the foundations of our prosperity, we were able to refocus our finite capacities on what regulatory environment would be optimal for Guernsey's long term competitiveness over the next decade or so, taking into account the considerably changed international environment. Over the course of the year we made considerable improvements, working in partnership with thoughtful industry actors, the States and Guernsey Finance. We look forward to delivering further beneficial reforms through 2026 and beyond.”

Commission Chairman John Aspden added: “The Commission has continued to deliver strong regulatory outcomes while remaining responsive to change in the external environment. Our focus is on maintaining the Bailiwick’s reputation as a well-regulated and forward-looking jurisdiction, while supporting sustainable growth and protecting users of financial services.”

Please be advised that details in respect of the following individual, who has been designated under the Global Anti-Corruption Sanctions Regulations 2021 (the UK regulations), have been amended:

• Sarju RAIKUNDALIA (Unique ID: GAC0051)

The above entity is still subject to an Asset Freeze, Travel Ban and Director Disqualification Sanction.

The entity referred to above appears on the UK sanctions list, which can be found here.

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).

MEASURES WHICH SHOULD BE TAKEN

All businesses must check whether they maintain any accounts or otherwise have any kind of relationship with the individual 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
• that comprise interest, dividends or other forms of property derived from any funds or economic resources that belong to them or are owned, held or controlled by them, whether directly or indirectly and 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 sanctions@gov.gg with the subject line “Global Anti-Corruption sanctions”.

Where you have identified an affected relationship as set out above, please also inform the Guernsey Financial Services Commission via email to amlcft@gfsc.gg providing short form information on the nature of the sanction connection and the measures you have taken or intend to take.

Handbook Rule 12.37, requires that, 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 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 the effect of asset freezes and related issues including licences is available on the States of Guernsey website at http://www.gov.gg/sanctions.

Please be advised that the details of the following entries have been amended on the UK Sanctions list:

The persons/entities listed above are designated under the Irregular Migration and Trafficking in Persons Sanctions Regulations 2025 (the UK Regulations) and appear on the UK sanctions list, which can be found here.

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).

MEASURES WHICH SHOULD BE TAKEN

All businesses must check whether they maintain any accounts or otherwise have any kind of relationship with the persons/entities 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
• that comprise interest, dividends or other forms of property derived from any funds or economic resources that belong to them or are owned, held or controlled by them, whether directly or indirectly and 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 sanctions@gov.gg with the subject line “Global Irregular Migration Sanctions”.

Where you have identified an affected relationship as set out above, please also inform the Guernsey Financial Services Commission via email to amlcft@gfsc.gg providing short form information on the nature of the sanction connection and the measures you have taken or intend to take.

Handbook Rule 12.37, requires that, 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 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 the effect of asset freezes and related issues including licences is available on the States of Guernsey website at http://www.gov.gg/sanctions.

Please be advised that the following individuals/entities have been designated under the Russia (Sanctions) (EU Exit) Regulations 2019 (the UK regulations): 

The individuals/entities referred to above appear on the UK sanctions list, which can be found here.

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).

MEASURES WHICH SHOULD BE TAKEN

All businesses must check whether they maintain any accounts or otherwise have any kind of relationship with the individuals/entities 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
• that comprise interest, dividends or other forms of property derived from any funds or economic resources that belong to them or are owned, held or controlled by them, whether directly or indirectly and 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 sanctions@gov.gg 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 amlcft@gfsc.gg providing short form information on the nature of the sanction connection and the measures you have taken or intend to take.

Handbook Rule 12.37, requires that, 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 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 the effect of asset freezes and related issues including licences is available on the States of Guernsey website at http://www.gov.gg/sanctions.