Guernsey, Alderney and Sark, being islands within the Bailiwick, each have their own legislative assembly and elected government. By and large they share an administrative, fiscal and legal system.   

Guernsey follows UK and UN sanctions which are implemented under the Sanctions (Implementation of UK Regimes) (Bailiwick of Guernsey) (Brexit) Regulations 2020 made under the Sanctions (Bailiwick of Guernsey) Law 2018.   

Travel bans are implemented under the Immigration (Guernsey) Order 1993 rather than under specific sanctions legislation 

Guernsey has the power to make designations under its Terrorist Asset-Freezing (Bailiwick of Guernsey) Law, 2011 but to date it has not exercised that power.  

Arms embargoes and related export restrictions are principally implemented by way of the Export Control (Military, Security, and Related Matters) (Bailiwick of Guernsey) Order 2010, which implements restrictions under the UK’s Export Control Order 2008. 

Guernsey may make modifications to the UK legislation through its own laws to ensure its sanctions regime works domestically. 

National Competent Authorities

The Policy & Resources Committee administers the Bailiwick’s sanctions regimes and the Financial Services Commission has responsibility for supervising firms’ controls in this respect and posts notices on its website.  The Financial Intelligence Unit shares notices to users on its THEMIS portal.

Sanctions Lists

Guernsey does not operate an independent sanctions list from the UK.  The UK sanctions list is on the UK page of this site.


Guernsey does not automatically adopt General Licences issued by the Office of Financial Sanctions Implementation and as such they do not have direct effect but in certain circumstances it may choose to do so. Further, the Policy & Resource Committee may independently issue a General Licence insofar as the UK sanctions provide for General Licences to be issued 

Licenses in respect of financial sanctions – a guide

Template for making licence requests

INT/2022/1280976  – Russia: Regulatory Authorities – Prudential Supervision or Financial Stability

INT/2022/1280876 – Russian Banks – UK subsidiaries – Basic needs, routine holding and maintenance and the payment of legal fees

INT/2022/1322576 – Provision of navigational data to civilian aircrafts for flight safety

INT/2022/1845976, “Crown Servants, Contractors & their Family Members”

INT/2022/1678476, “Amsterdam Trade Bank N.V – winding down, basic needs and insolvency related payments”

INT/2023/2589788, “Wind down of Trust Services provided to Designated Persons”

General Licence – RUSSIA/GY/2022/1

General Licence – RUSSIA/GY/2022/2

General Licence – GY/RUSSIA/2022/6

General Licence – RUSSIA/GY/2022/9

General Licence – RUSSIA/GY/2022/18

General Licence – RUSSIA/GY/2022/21

General Licence – GY/RUSSIA/2023/17

General Licence — GY/ RUSSIA /2024/4

General Licence – RUSSIA/GY/2024/GL2



In general terms, breach of sanctions in Guernsey is a criminal offence.

Guernsey does not have the power to issue civil penalties for breach of sanctions.


Guidance on reporting obligations

There are specific reporting obligations applicable to businesses that are subject to Guernsey’s sanctions regime under the Sanctions (Bailiwick of Guernsey) Law, 2018 and the Terrorist Asset-Freezing (Bailiwick of Guernsey) Law, 2011; reporting obligations may also arise from specific UK sanctions.

Reports are made to the Policy & Resources Committee.

Export controls

Arms embargoes and related export restrictions are principally implemented in the Bailiwick under general export control legislation rather than by specific sanctions legislation. 

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. 

Export Licence Controls

Application for export licence for strategic goods


Applications for de-listing are made by completing a Sanctions Review Request Form and sending it to the Policy & Resources Committee, containing information on the identity of the person, the nature of the application (variation or revocation), and the basis on which it is claimed that the designation should be varied or revoked.

Supporting evidence should, as far as possible, be evidence from independent and reliable sources, evidence that can be verified and corroborating evidence.

The Policy & Resources Committee will take all reasonable steps to make a determination on an application as soon as possible after receiving all necessary information and documents, either from the applicant or from any third party. Priority will be given to cases of particular urgency.

Under section 24 of the TAFL, there is a right of appeal against refusals to vary or revoke designations.  An appeal may be made on one or more of the following grounds: (a) the decision was ultra vires or there was some other error of law (b) the decision was unreasonable (c) the decision was made in bad faith (d) there was a lack of proportionality (e) there was a material error as to the facts or as to the procedure.

The Guernsey Policy & Resources Committee cannot revoke or vary designations made by the UN or UK, but it can make requests to the FCDO de-list the individual or to make a de-listing requests to the UN where the grounds put forward by the DP are “sufficient”.

Unfreezing of funds

Individuals who have the same names as a designated person so adversely affected by sanctions, and recently de-listed individuals, who are finding difficulty with the unfreezing of their assets, may send an application for assistance with unfreezing to the Policy and Resources Committee.

Entities which are holding frozen assets must contact the Policy & Resources Committee before taking any action in relation to a suspected false positive case (i.e. where assets have been frozen of a suspected non-DP).

Links and resources:

Unfreezing guidance

Guidance on applications for revocation or variation of designations

Guidance for applications for assistance with challenging UK and UN designations

Sanctions Review Request Form