Sanctions Notice - Russia

2nd June 2023

Please be advised that the UK’s Office of Financial Sanctions Implementation (OFSI) has published a blog post in relation to the prohibition on the provision of trust services under the Russia (Sanctions) (EU Exit) Regulations 2019 (the UK regulations). The blog post, which is available here: Trust Services Sanctions – 5 months on - OFSI (, contains guidance on the approach taken by OFSI to the implementation of the prohibition and the application of General Licence INT/2023/2589788 that was issued by OFSI on 21 March 2023.

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). As advised in a previous sanctions notice, the Policy & Resources Committee has issued a general licence (available here – General Licence GY/RUSSIA/2023/17) which is in similar terms to the OFSI general licence.

While the approach set out in the blog post is not binding on the authorities in the Bailiwick, in practice they are likely to take a similar approach to the implementation of the trusts services prohibition and the application of the general licence issued by the Policy & Resources Committee. Businesses are therefore advised to familiarise themselves with the content of the blog post.

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

Where you have identified a connection to a designated person 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