Sanctions Notice - Russia

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

Name	OFSI ID	Unique ID
ABSOLUT TRADE LLC	17158	RUS3053
MAXCOMM LLC	17159	RUS3054
NPK PROGRESS	17160	RUS3055
IZZITION E-TECHNOLOGY CO LTD	17161	RUS3056
LLC HARTIS DV	17162	RUS3057
LMM ELECTRONICS (FZE)	17164	RUS3059
S-MIKRON ELEKTRONIK ELEKTRIK SANAYI TAAHHUT TICARET ANONIM SIRKETI	17165	RUS3060
INOI INTERNATIONAL FZ LLC	17166	RUS3061
PJSC Rosneft Oil Company	17169	RUS3064
NAYARA ENERGY LIMITED	17170	RUS3065
ALT CAPITAL PTE LTD	17171	RUS3066
PERGAM-ENGINEERING JSC	17174	RUS3069
ELECTRA PRO LLC	17175	RUS3070
SHENZHEN JLFY TECHNOLOGY CO., LTD	17176	RUS3071
SURE TECHNOLOGY (HONGKONG) COMPANY LTD	17177	RUS3072
HORSWAY TECH (HK) CO., LIMITED	17178	RUS3073
MSUNTECH ELECTRONICS (GROUP) CO., LIMITED	17179	RUS3074
YW NL E-COMMERCE COMPANY	17180	RUS3075
JSC NATIONAL CARD PAYMENT SYSTEM (NSPK)	17181	RUS3076
JSC SOLID BANK	17182	RUS3077
PUBLIC JOINT-STOCK COMPANY SOCIAL COMMERCIAL BANK OF PRIMORYE PRIMSOTSBANK	17183	RUS3078
JSC TRANSSTROIBANK	17184	RUS3079
JSC BBR Bank	17185	RUS3080
CHINA THAI CORPORATION GROUP CO., LTD	17186	RUS3083
ALGHAF MARINE DMCC	17187	RUS3086
WISSOL COMMODITIES FZCO	17188	RUS3087
SHANDONG YULONG PETROCHEMICAL COMPANY	17190	RUS3089
SHANDONG JINGANG PORT CO., LTD	17191	RUS3090
NATIONAL PIPELINE GROUP BEIHAI LIQUEFIED NATURAL GAS CO LTD	17192	RUS3091
SHANDONG HAIXIN PORT CO. LTD	17193	RUS3092
SHANDONG BAOGANG INTERNATIONAL PORT CO. LTD	17194	RUS3093
PJSC Oil Company LUKOIL	17195	RUS3094
ARS Global LLC	17196	RUS3095
LMSISTEMS LLC	17197	RUS3096
Dmitriy Alekseevich DMITRIEV	17163	RUS3058
Maxim Nikolaevich KRASNOV	17167	RUS3062
Maxim Viktorovich AGEEV	17168	RUS3063
Vladislav GROMOV	17172	RUS3067
Narmina DADASHOVA	17173	RUS3068

The individuals/entities referred to above are now subject to an asset freeze and trust service sanctions, and appear on the UK’s consolidated 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 [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.

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.