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Sanctions Notice – Central African Republic | Guernsey Financial Services Commission

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Please be advised that the UN Security Council Committee concerning the Central African Republic has added Bi Sidi Souleman to its sanctions list, on the basis of his leadership of the CAR militia group, Retour, Réclamation, Réhabilitation (3R). 3R is said to have “killed, tortured, raped, and displaced civilians, and engaged in arms trafficking, illegal taxation activities, and warfare with other militias since its creation in 2015”. Mr Souleman is alleged to have participated directly in acts of torture. For more information, see the UN press release, available here.

Under section 13 of the Sanctions (Bailiwick of Guernsey) Law, 2018 (the Sanctions Law), this amendment is deemed to have been made to the list maintained by the European Union under EU Regulation No 224/2014 and is therefore automatically effective in the Bailiwick under theCentral African Republic (Restrictive Measures) (Guernsey) Ordinance, 2014.

MEASURES WHICH SHOULD BE TAKEN

All businesses must check whether they maintain any accounts or otherwise have any kind of relationship with the person referred to above or to any other natural or legal person, entity or body designated under the legislation referred to above and must treat any funds, other assets or economic resources 

  • directly or indirectly belonging to, owned, held or controlled by them, whether wholly or jointly,  or
  • derived from any funds or economic resources directly or indirectly belonging to, owned, held or controlled by them, whether wholly or jointly,  or
  • belonging to individuals or entities acting on their behalf or at their  direction, whether wholly or jointly

as frozen with immediate effect if this is not already the case. Businesses must report any findings to the Policy & Resources Committee immediately, and must 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.

Businesses must also refrain from making any funds or economic resources available directly or indirectly, wholly or jointly, to or for the benefit of

  • any designated person, entity or body
  • any entity directly or indirectly owned or controlled by a designated person, entity or body, whether wholly or jointly
  • any individuals or entities acting on behalf or at the  direction of a designated person, entity or body, whether wholly or jointly

other than in respect of transactions that come within a permitted derogation as determined by the Policy & Resources Committee, or in accordance with a licence issued by the Policy & Resources Committee, as the case may be.

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 and under the Schedule to the Ordinance mentioned above. 

Any information or queries should be sent to [email protected] with the subject line “CAR Sanctions”.

Further information on the effect of asset freezes and related issues including licences is available on the States of Guernsey website at http://www.gov.gg/sanctions

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