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ARTICLE · 10 OCTOBER 2024

Sanctions Reporting: Episode I - The Phantom Menace

Collas Crill
Collas Crill
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Collas Crill

Collas Crill

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The Guernsey sanctions laws require institutions to report suspected links to designated persons, with new obligations to report to the Guernsey Financial Services Commission and maintain a detailed register of these reports.

GuernseyFinance and Banking
Michael Adkins
Michael Adkins
Nin Ritchie
Nin Ritchie
Amy Davies
Amy Davies
Alice Allen
Alice Allen
Aimee Brown
Aimee Brown
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The Sanctions (Bailiwick of Guernsey) Law, 2018 (the Sanctions Law) and the Terrorist Asset-Freezing (Bailiwick of Guernsey) Law 2011 (the Laws) have been around for some time, so most of us are aware of our obligation to make a report to the Policy and Resources Committee (the Committee) under them.

Reporting obligations up to now

By way of a quick reminder, the Laws state that if you are a relevant institution (as defined in the Laws) you have an obligation to make a report to the Committee if during the course of carrying on your business:

  1. you know or have reasonable cause to suspect that:
    1. a person is or is linked to a designated person; or
    2. a person has committed an offence under the Laws, or; in the case of the Sanctions Law, its subordinate provisions; or

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