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Sanctions Notice - Russia

2nd March 2022

Please be advised that, in light of recent events in Ukraine, the UK has made some amendments to the Russia (Sanctions) (EU Exit) Regulations 2019 (the UK Russia regime). The UK Russia regime is implemented in the Bailiwick by the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations, 2020 (the Bailiwick regulations).

The amendments to the UK Russia regime introduce new financial sanctions that are applicable to dealings with parties linked to Russia. These new financial sanctions extend the sanctions prohibitions to a broad range of transferable securities and money market instruments as well as to loans and credit. They also introduce new restrictions on correspondent banking relationships and processing of sterling payments, and widen the power to make designations.  

The amendments also introduce new trade and maritime sanctions, which in the case of trade sanctions include prohibitions on the provision of related technical assistance, financial services, and funds and brokering services.  

Under the Bailiwick regulations the amendments are automatically effective in the Bailiwick. However, the Policy & Resources Committee has made some amendments to the Bailiwick regulations which concern the modification of UK sanctions in their application to the Bailiwick. These amendments have been made to facilitate the effective implementation in the Bailiwick of the new Russian sanctions measures introduced by the UK. A copy of the amendment regulations (the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) (Amendment) Regulations, 2022) is attached to this notice.

Further details of the new sanctions measures and guidance about their application are available on the website of the UK's Office  of Financial Sanctions Implementation, accessible via this link; Russia sanctions: guidance - GOV.UK (www.gov.uk)

MEASURES WHICH SHOULD BE TAKEN

All businesses must familiarise themselves with the new sanctions measures and related guidance provided by the UK. They must check whether they have any business relationships that may be relevant and report any findings must be reported to the Policy & Resources Committee immediately. Businesses 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 should refrain from carrying out any activity that is prohibited by the UK Russia regime other than in accordance with a licence issued by the Policy & Resources Committee.

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”.

Further information on the effect of sanctions measures including licences is available on the States of Guernsey website at http://www.gov.gg/sanctions