Introduction
1. The Global Anti-Corruption (Sanctions) (EU Exit) Regulations 2021 (the “UK Regulations") were made under the Sanctions and Anti-Money Laundering Act 2018 and provide for the imposition of financial sanctions, namely the freezing of funds and economic resources persons who are or have been involved in serious corruption
2. On 21 November 2024 the Foreign, Commonwealth and Development Office updated the UK Sanctions List to reflect changes to those persons designated under the UK Regulations. A link to the UK Sanctions List can be found below
3. The Sanctions and Asset-Freezing (Implementation of External Sanctions) (Jersey) Order 2021, made under the Sanctions and Asset-Freezing (Jersey) Law 2019 (“SAFL"), links to the UK Regulations
4. Any changes to asset-freeze designations made under the UK Regulations are effective immediately by virtue of the ambulatory provisions in Jersey's sanctions legislation
5. An asset freeze now applies to the individuals listed in the Annex to this Notice under Part 3 of SAFL
Notice summary
6. Find full details in the Annex to this notice
7. The following entries have been made and are now subject to an asset freeze:
Isabel DOS SANTOS (UK Consolidated Group ID: 16694)
Dmitry Vasylovych FIRTASH (UK Consolidated Group ID: 16699)
Lada Pavlovna FIRTASH (UK Consolidated Group ID: 16700)
Denis Vladimirovich GORBUNENKO (UK Consolidated Group ID: 16701)
Liga LEMBERGA (UK Consolidated Group ID: 16698)
Aivars LEMBERGS (UK Consolidated Group ID: 16697)
Paula Cristina Fidalgo Carvalho Das Neves OLIVEIRA (UK Consolidated Group ID: 16696)
Sarju RAIKUNDALIA (UK Consolidated Group ID: 16695)
What you must do
8. You must:
immediately check whether you maintain any accounts or hold any funds or economic resources for the persons set out in the Annex to this Notice
freeze such accounts, and other funds or economic resources without prior notice and without delay
refrain from dealing with the funds or assets of making them available (directly or indirectly) to such persons unless licensed by the Minister for External Relations (“MER")
report any findings to MER, together with any additional information that would facilitate compliance with SAFL
provide any information concerning the frozen assets of designated persons that MER may request. Information reported to MER may be passed on to other regulatory authorities or law enforcement
9. Failure to comply with sanctions legislation or to seek to circumvent its provisions is a criminal offence
Further information
10. Find guidance on unfreezing assets for delisted persons or entities
11. Further information on sanctions can be found on Government of Jersey and Jersey Financial Services Commission (JFSC) websites
12. Jersey guidance on the Global Anti-Corruption sanctions regime is available at JFSC Sanctions by country and category
13. A copy of the UK Regulations can be obtained from legislation.gov.uk. Other relevant information about this regime can be found on financial sanctions targets by regime on GOV.UK
14. The UK Sanctions List on GOV.UK
15. The UK Office of Financial Sanctions Implementation Consolidated List on GOV.UK
Enquiries
16. Non-media enquiries, sanctions compliance reporting, and licence applications should be emailed to the Financial Sanctions Implementation Unit at sanctions@gov.je
Annex
17. 
Annex to Financial Sanctions Notice Global Anti-Corruption 21 November 2024
gov.je