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Sanctions

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Sanctions are used as an enforcement tool to maintain and restore international peace and security: these sanctions are made by the United Nations Security Council (UNSC) and must be implemented by all UN members.

Sanctions are also used as a foreign policy tool by individual states, or groups of countries working together, when all other diplomatic methods have failed. These sanctions are sometimes referred to as autonomous sanctions and are made outside the UNSC framework.

In addition to UNSC sanctions, the UK also implements its own autonomous sanctions. Guernsey implements both UNSC sanctions and autonomous UK sanctions.

Sanctions are used:

Sanctions are only used in the most serious of circumstances. In international relation terms the only action considered more serious than sanctions is military action. Countries usually try to achieve their aims diplomatically, but if that is not possible they may introduce sanctions.

A wide range of measures can be enforced under sanctions regimes, from asset-freeze designations (see below for more information on asset-freezes) to restrictions on the import or export of specified goods, and prohibitions on the provision of financial and other services.

How sanctions are implemented

Though Guernsey is not a UN member in its own right, the UK's membership of the UN extends to the island. Therefore, in common with all UN members, Guernsey has an obligation to implement UNSC sanctions Resolutions.

Both UNSC sanctions and autonomous UK sanctions are implemented by the UK under the relevant sanctions Regulations made under the Sanctions and Money Laundering Act 2018 ("SAMLA").

Guernsey implements both UNSC sanctions and autonomous UK sanctions by implementing the relevant SAMLA Regulations.

For information on the sanctions regimes which are in place follow this link. Updates on new sanctions regimes and changes to existing regimes are available here, including changes to designations which are uploaded on the website as soon as they are made.You can also find out more information from this   frequently asked questions document [283kb]. The UK Office of Financial Sanctions Implementation at HM Treasury has also issued an FAQ document on sanctions which is available by following this link and the UK Financial Conduct Authority has issued guidance on financial crime that includes sanctions which is available by following this link. These documents are not binding on the Guernsey authorities but they may take them into account when considering any question of implementation within the Bailiwick.

The United Nations and the European Union are key bodies that adopt sanctions measures. In addition, as a result of the United Kingdom leaving the European Union, the UK now enacts its own sanctions measures. These measures may be autonomous sanctions regimes or may implement a UN sanctions regimes. UK autonomous sanctions regimes that replace corresponding EU sanctions regimes are broadly similar to, but not identical to, those EU regimes. Sanctions may implement the following measures:

Sanctions against Russia

The UK's recent sanctions made against Russia in response to the war in Ukraine have automatic effect in the Bailiwick. The Policy & Resources Committee has made new sanctions Regulations to ensure these sanctions are adapted, with very minor changes, for the Bailiwick's domestic context.

These Regulations are made in a coordinated way with the UK to ensure the latest sanctions announced are adapted to meet the domestic context.

 The Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) (Amendment) Regulations, 2022 [65kb]

 The Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) (Amendment) (No.2) Regulations, 2022 [47kb]

Please be advised that the UK has updated its Russia guidance in line with the current and emerging circumstances of Russia's invasion of Ukraine.

All businesses are required to be proactive in monitoring the emergence of new sanctions and the changes to previous designations. All actions taken by the UK in regard to Russia sanctions can be found at this address as soon as they are made:

Financial sanctions, Russia - GOV.UK (www.gov.uk)

Designated persons are subject to an asset freeze and will appear on the consolidated list, which can be found here.

The Policy & Resources Committee is carrying out a review of frozen assets linked to persons designated under the Russia (Sanctions) (EU Exit) Regulations 2019 (the Russia regime). The purpose of the review is to enable the Policy & Resources Committee to update its records in respect of assets frozen under the Russia regime. Businesses that hold or control frozen assets, or which have an ongoing connection to frozen assets outside the Bailiwick, are therefore requested to complete this  template [18kb] and submit it to the Policy & Resources Committee by 24 November 2023.

Further information on the current sanctions in place in in the Bailiwick against Russia is available here.

Further information on the Bailiwick's response to the war in Ukraine is available here.

  • Legislation

    • The Bailiwick implements all types of international sanctions.
    • Travel bans are implemented administratively under the Immigration Act 1971, as extended to the Bailiwick by the Immigration (Guernsey) Order 1993, rather than under specific sanctions legislation.
    • Arms embargoes and related export restrictions are principally implemented in the Bailiwick under general export control legislation rather than by specific sanctions legislation (although there may be an overlap with Guernsey's specific sanctions legislation in cases where this includes certain import and export restrictions).  The relevant legislation is the Export Control (Military, Security, and Related Matters) (Bailiwick of Guernsey) Order, 2010. This Order expressly mirrors and incorporates restrictions under the UK's Export Control Order 2008 and any changes made under the UK Order are automatically effective under the Guernsey Order. The Committee for Home Affairs, through the Guernsey Border Agency, is the competent authority for any import or export licensing matters. Further information about the restrictions in place under export control legislation is available by following this link.
    • All other forms of sanctions, including regime-specific sanctions, are implemented in the Bailiwick under the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations, 2020 (the 2020 regulations). The 2020 regulations give effect in the Bailiwick to sanctions regimes enacted by the UK under the Sanctions and Anti-Money Laundering Act 2018 (the SAML Act). Further details are set out in the section on Brexit below. 
    • It is the responsibility of each individual or institution to comply with the relevant legislation and failure to comply is a criminal offence.
    • It is important to note that changes to sanctions measures are automatically effective under the 2020 regulations. These changes may involve the addition of further prohibitions or, more commonly, the adding or removing of names from lists of designated persons or entities targeted by a particular sanctions regime. It is particularly important to be aware that where a UN list is incorporated into a UK sanctions regime that has been implemented in the Bailiwick under the 2020 regulations, any additions to the UN list are automatically effective domestically. Therefore, in order to be aware of the full scope of sanctions under a UK sanctions regime or UN Security Council Resolution at a particular time, all amendments made to the UK sanctions regime or Resolution in question up to that time must be taken into account.
  • Brexit

    • As a result of Brexit, the UK has introduced the Sanctions and Anti-Money Laundering Act 2018 (the SAML Act), under which it both gives effect to UN sanctions and enacts its own autonomous sanctions regimes  instead of, as previously, implementing sanctions via EU Regulations.
    • The Bailiwick's policy is to ensure that the sanctions regime applicable domestically continues to mirror that in the UK. Therefore, a number of legislative steps to achieve this have been put in place. First, under the Sanctions (Bailiwick of Guernsey) Law, 2018, the Policy & Resources Committee has enacted the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations, 2020 ( the 2020 regulations), which came into force on 31st December 2020. The 2020 regulations give effect to all of the UK sanctions regimes under the SAML Act to date, and repeal the Ordinances giving effect to corresponding EU sanctions measures. They also contain transitional provisions which specify that any licences or licence applications in existence as at 31st December 2020 are deemed to have been made under the 2020 regulations (subject to any applicable restrictions or conditions in the case of existing licences). The 2020 regulations will be amended to add any future sanctions that may be enacted by the UK under the SAML Act as they come into force.
    • Second, the Sanctions (Bailiwick of Guernsey) Law, 2018 has been amended to repeal provisions that gave interim effect to UN sanctions measures before they had been adopted by the EU. Interim provision of this kind is no longer necessary, as changes to UN measures are automatically effective under the UK sanctions regimes that implement them, and therefore are automatically effective in turn under the 2020 regulations.
    • Third, the definition of designated person under the Terrorist Asset Freezing (Bailiwick of Guernsey) Law, 2011, has been amended. It previously included persons designated by the UK under the Terrorist Asset Freezing etc. Act, 2010 or by the EU under a specific terrorism-related sanctions regime. The definition of designated person now only covers persons designated by the Policy & Resources Committee. This reflects the fact that in the UK, designations under the UK Act and the EU regulation have been replaced by two dedicated terrorist asset-freezing regimes under the SAML Act, and those regimes are implemented in the Bailiwick by the 2020 regulations.
  • Reporting Obligations

    • Under the Sanctions (Bailiwick of Guernsey) Law, 2018, there are specific reporting obligations applicable to businesses that are subject to the Bailiwick's regime for countering money laundering and terrorist financing. Reports should be made using this form - pdf icon Sanctions Compliance Reporting Form [300kb]. Further information is available here: pdf icon Guidance on reporting obligations 2024 [149kb]. In addition, the UK sanctions regimes implemented in the Bailiwick are subject to particular reporting obligations which in some cases are generally applicable. These obligations vary depending on the regime in question, but they primarily relate to financial restrictions. Details of the applicable reporting obligations are available by following this link.
  • Financial Restrictions

    • The Bailiwick's position as a leading international financial sector means that financial restrictions are the most likely to be relevant to businesses in this jurisdiction. As well as comprehensive prohibitions on dealing with sanctioned countries and their governments, financial restrictions include targeted measures such as asset freezes and prohibitions on providing specific financial services or making funds or other economic resources available to designated individuals or entities. Generally speaking, any person who fails to treat as frozen all accounts, funds or economic resources belonging to, owned, held or controlled by a designated person, entity, body or group, or who makes any funds, economic resources (or, in some circumstances, financial or technical assistance) available directly or indirectly to or for the benefit of designated persons, is guilty of an offence unless the transaction in question has been licensed (see section on licences below).
    • It is important to be aware that asset freezes and prohibitions on making funds or economic resources available apply irrespective of whether the relevant assets are held solely by a designated person or are held jointly with a third party, and they extend to interest and other assets that  are derived from the assets subject to an asset freeze.
    • Changes to the lists of designated persons or entities targeted by a particular UK sanctions regime (whether this is an autonomous UK regime or implements a United Nations Security Council Resolution) are automatically effective in Guernsey. They are incorporated into lists maintained by HM Treasury when they are made by the appropriate designating body. As well as regime -specific lists, HM Treasury maintains a consolidated list of designated persons under all regimes. It is the responsibility of each individual or institution to familiarise itself with changes to designations by checking these lists. The United Nations maintains a mailing list for updates to its listings, which can be accessed by sending a request to subscribe to the mailing list to sc-sanctionslists@un.org. HM Treasury's Office of Financial Sanctions Implementation also provides updates on listings, which can be signed up to here - Get emails from GOV.UK - GOV.UK (www.gov.uk). In addition to these sources of information, the Policy & Resources Committee issues Sanctions Notices which provide updates on listings. These are circulated on behalf of the Policy & Resources Committee by the Financial Intelligence Unit. Any person who wishes to sign up to receive Sanctions Notices should contact the Financial Intelligence Unit at fiu@gba.gov.gg.
    • pdf icon Targeted Financial Sanctions - Overarching Guidance on Compliance for Firms [217kb]
    • Regime-specific and consolidated lists of financial sanctions targets can be found on the HM Treasury website.
  • Licences

    • A licence is a written authorisation from a named competent authority to allow an activity which would otherwise be prohibited by sanctions measures.
    • Under the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations, 2020 (the 2020 regulations), the Bailiwick competent authority for licences in respect of financial services and related matters is the States of Guernsey Policy & Resources Committee. The Policy & Resources Committee is also the competent authority under the Terrorist Asset - Freezing (Bailiwick of Guernsey) Law, 2011. The Bailiwick competent authority for trade licences (i.e. licences related to matters such as import or export and shipping) is the States of Guernsey Committee for Home Affairs. 
    • There are record keeping obligations relating to licences under the UK sanctions regimes that are implemented by the 2020 regulations and are therefore also applicable in the Bailiwick.  
    • All applications for licences should be addressed to the Financial Crime Policy Office of the Policy & Resources Committee in the first instance. Further information on licence applications in relation to financial sanctions is available to download pdf icon here. [160kb]
    • Please be advised that a template has been developed for making requests to the Policy & Resources Committee for a licence under the sanctions framework. The template is available  here [196kb].
    • In addition, the  Policy & Resources Committee has issued general licences under regulation 64 of the UK regulations as applied in the Bailiwick. The general licences are available to download:  here [165kb],  here [161kb],  here [206kb],  here [159kb],  here [160kb],  here [155kb],  here [172kb] and  pdf icon here [2Mb]. They replicate within the Bailiwick the effect of some general licences that have been issued in the UK to permit activity which would otherwise be in breach of the Russia sanctions regime. The UK licences are available here: OFSI General Licences - GOV.UK (www.gov.uk). The general licences are subject to the same terms, conditions and expiry dates as the UK general licences, as well as to some modifications to reflect the Bailiwick context. Any business that intends to rely on the general licences should inform the Policy & Resources Committee in advance. This information referred to above is required by the Policy & Resources Committee in the exercise of its powers under section 15 of the Sanctions Law.
  • Unfreezing and De-Listing

    • It may sometimes happen that assets are frozen in the belief that they are linked to a designated person when that is not in fact the case. The Policy & Resources Committee may assist with unfreezing any assets in the Bailiwick to which this applies, provided that it is satisfied that the assets are not linked to a designated person. Guidance on the procedures to follow if requesting assistance with unfreezing assets is available here - pdf icon Unfreezing Guidance [147kb].
    • The Policy & Resources Committee may also assist with requests to be removed from a list of designated persons in appropriate cases. The Policy & Resources Committee may vary or revoke its own designations made under the Terrorist Asset Freezing Law, if satisfied that it is appropriate to do so. In addition there is a right of appeal against decisions as to designations made by the Policy & Resources Committee under section 24 of the Terrorist Asset Freezing Law. This is available to any person who is aggrieved by a particular decision, not just to the designated person. Guidance on applications to vary or revoke  a designation under the Terrorist Asset Freezing Law is available here - pdf icon Guidance on applications for revocation or variation of designations [127kb]
    • The Policy & Resources Committee cannot amend or revoke designations made by other designating authorities such as the UN, the EU or the UK, but it may be able to assist a listed person within the Bailiwick in dealing with the relevant designating authority.
    • Guidance on applications for assistance with challenging UN or UK designations is available here - pdf icon Guidance for applications for assistance with challenging UK and UN designations [142kb]. Any person wishing to make a de-listing request or challenge in respect of a designation under the Terrorist Asset Freezing Law, or to request the assistance of the Policy & Resources Committee in relation to a UK or UN designation, should do so by completing a sanctions review request form available here pdf icon Sanctions Review Request Form [197kb], which should be sent by email or post to:
    • Financial Crime Policy Office
      Sir Charles Frossard House
      La Charroterie
      St Peter Port
      Guernsey
      GY1 1FH
      Channel Islands
      Tel: +44 1481 223220
      Email: policyandresources@gov.gg 
    • De-listing requests or challenges may also be addressed directly to the relevant designating authority as follows:
    • United Nations - any person who wishes to be removed from any UN sanctions list can access the United Nations focal point for delisting and obtain further information here. Requests to be removed from the ISIL (Da'esh) and Al-Qaida Sanctions List of the Security Council's ISIL (Da'esh) and Al-Qaida Sanctions Committee may also be submitted for review by an independent and impartial Ombudsperson. Further details are available here.
    • Alternatively a person may petition his or her state of residence or citizenship. British citizens should  send the petition with the details specified by the UN to:
    • Foreign and Commonwealth Office
      King Charles Street
      London
      SW1A 2AH
    • UK - any persons designated or listed under a UK sanctions regime, including UN listed persons,  can make a request to the UK for revocation, variation or review of their designation. This may be done by completing a UK review request form. In addition, under Chapter 4 of the Sanctions and Anti-Money Laundering Act 2018, there is a right to a court review of any ministerial decisions on designations.
    • European Union - requests to be removed from listings under EU Regulations may be sent to relex-sanctions@ec.europa.eu
  • Proposals for Designation

    • The Policy & Resources Committee's role as competent authority for financial sanctions includes making proposals to the United Nations Security Council for designations under UN sanctions regimes (or the UK for designations under the UK's autonomous sanctions regime). This applies to all regimes but is particularly important in respect of regimes related to activities that threaten global security such as terrorism or the proliferation of weapons of mass destruction, and to the financing of those activities. 
    • The Policy & Resources Committee also has the power to make its own designations under the Terrorist Asset Freezing (Bailiwick of Guernsey) Law, 2011 in respect of an individual or entity  if it has reasonable grounds to suspect that the individual or entity  is  involved in terrorist activity, is owned or controlled directly or indirectly by a person involved in terrorist activity, or is  acting on behalf of or at the direction of a person involved in terrorist activity. 
    • The Policy & Resources Committee will consider making designation proposals, or its own designations under the Terrorist Asset Freezing Law, on the basis of information provided by third parties. This includes making designations under the Terrorist Asset Freezing Law to freeze assets at the request of  other jurisdictions. Guidance to assist other jurisdictions in making a designation request under the Terrorist Asset Freezing Law is available pdf icon here [170kb]. In the event that a designation is made by the Policy & Resources Committee, the Policy & Resources Committee will also consider whether there are assets linked to the designated person in another jurisdiction and if so, whether to request that jurisdiction to freeze the assets.
    • As well as considering information from other domestic authorities or from the authorities in other jurisdictions, the Policy & Resources Committee will take into account information from industry or from the third sector. Businesses and charities, especially those with international links, should therefore keep in mind the importance of identifying any possible designation targets, whether for designation by the UN, the UK or the Policy & Resources Committee (and, if the Policy & Resources makes a designation under the Terrorist Asset Freezing Law, whether there are any assets linked to the designated person located in another jurisdiction). Any person who wishes to provide information relating these matters should do so by completing a Designation Proposal Form available here pdf icon Designation Proposal Form [137kb], which should be sent by email or post to:
    • Financial Crime Policy Office
      Sir Charles Frossard House
      La Charroterie
      St Peter Port
      Guernsey
      GY1 1FH
      Channel Islands
      Tel: +44 1481 223220
      Email: policyandresources@gov.gg
  • Relationship to Other Jurisdictions

    • Although the Bailiwick's sanctions regime operates independently, trans-jurisdictional issues may arise at times. Many transfers of funds will be made to or from another jurisdiction that operates a sanctions regime and in such cases a licence may be required in both jurisdictions. unless there are specific measures in place to recognise a licence issued by the other jurisdiction. This is the case in the UK, which under its sanctions regimes recognizes licences issued by the Crown Dependencies or the Overseas Territories; as implemented in the Bailiwick, this recognition also includes licences issues by the UK.
    • In addition, the legislative frameworks of some jurisdictions contain provisions that are expressed to have extra-territorial effect, so that they may apply to some of the parties involved in a Bailiwick transaction on the grounds of nationality or place of incorporation even if the jurisdiction in question is not involved in that transaction.
    • The Policy & Resources Committee may also assist the sanctions authorities in other jurisdictions in an appropriate case. Queries should be sent to the Financial Crime Policy Office of the Policy & Resources Committee at:
    • Financial Crime Policy Office
      Sir Charles Frossard House
      La Charroterie
      St Peter Port
      Guernsey
      GY1 1FH
      Channel Islands
      Tel: +44 1481 223220
      Email: policyandresources@gov.gg 
  • EU Sanctions and United States Sanctions (OFAC)

    • Businesses in Guernsey should be aware of autonomous sanctions implemented by the European Union, or in the USA by the Office of Foreign Assets Control (OFAC).
    • EU sanctions apply to nationals of member states and any activity within a member state.
    • OFAC regulations can be applied to:
      • U.S. citizens and permanent residents regardless of where they are located.
      • Persons and entities within the United States.
      • Persons and entities trading in U.S. Dollars
      • U.S. incorporated entities and their foreign branches.
      • In the cases of certain sanctions, such as those regarding Cuba and North Korea, all foreign subsidiaries owned or controlled by U.S. companies.
      • Foreign persons in possession of U.S. origin goods in some cases
  • Administration of Sanctions Matters in Guernsey

    • The Sanctions Committee coordinates compliance with UN and UK sanctions and other relevant sanctions issued by supranational or international bodies. It also assists with ensuring  effective compliance with UN and other relevant sanctions.  
    • The Sanctions Committee comprises representatives from the Policy & Resources Committee and the Committee for Home Affairs, the Law Officers' Chambers, the Guernsey Financial Services Commission, the Alderney Gambling Control Commission, the Guernsey Registry, the Alderney Registry, Guernsey Customs, the Financial Intelligence Unit, the Economic & Financial Crime Bureau, the Revenue Service, Guernsey Harbour Master, and the Director of Civil Aviation.
    • The Policy & Resources Committee is mandated to:
      • enact regulations to implement new sanctions measures
      • license access to frozen funds and economic resources
      • make designations for asset freezing purposes in terrorism cases
      • make recommendations for designations by the UN and the UK
      • assist with requests for de-listing and the unfreezing of assets
    • The Policy & Resources Committee also works with HM Treasury and the Foreign and Commonwealth Office. 
    • For details regarding how the Committee processes personal data, please see the Data Protection page.

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