Sanctions Notice - Russia (further restrictions)

19th December 2022

Please be advised that the Russia (Sanctions) (EU Exit) Regulations 2019 (the UK regulations) have been amended by the Russia (Sanctions) (EU Exit) (Amendment) (No. 17) Regulations 2022 (the Amendment regulations).

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). The changes made by the Amendment regulations are effective in the Bailiwick as soon as they come into force in the UK.

The Amending regulations impose a number of further restrictions under the Russia regulations, (with corresponding changes to the provisions concerning record keeping, reporting, exemptions and licences). The further restrictions are as follows –

  1. the introduction of a restriction in relation to the provision of trust services (or services for similar legal arrangements) to designated persons or persons connected with Russia;
  2. the extension of certain financial and investment restrictions;
  3. the addition of further services to the existing provisions imposing restrictions relating to professional and business services;
  4. the addition of further items to the lists of prohibited goods and trade.

With the exception of some changes to trade-related restrictions, which come into force on 1 January 2023, the changes made by the Amending regulations are immediately effective.


All businesses must familiarise themselves with the new restrictions and check whether they maintain any accounts or otherwise have any kind of relationship that will be affected by the new restrictions. They should 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. NB: Where a business has previously made a report to the Policy & Resources Committee about a business relationship that would now be captured by the restriction at 1 above, no additional report should be made unless that relationship engages the restrictions at 2 to 4 above.

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 a connection 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. The Commission would also draw your attention to the updated Russia guidance document listed on the OFSI website (

Further information on the effect of asset freezes and related issues including licences is available on the States of Guernsey website at