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EU officials have issued a warning to EU banks about the first issuance of sovereign bonds by the Russian Federation since EU sanctions were imposed in 2014 following concerns about Russian involvement in the events in Ukraine.

The relevant sanctions have been implemented in the Bailiwick by the Russian Federation (Restrictive Measures) (Guernsey) Ordinance, 2014, the Russian Federation (Restrictive Measures) (Alderney) Ordinance, 2014 and the Russian Federation (Restrictive Measures) (Sark) Ordinance, 2014. While these sanctions do not prohibit the purchase of Russian sovereign debt, they significantly restrict the access of Russian state banks to international financial systems and the EU has advised that banks should be alert to the possibility that the bonds may be used to circumvent these restrictions. The EU has also recommended putting preventive measures in place, such as clauses that prevent funds generated by the sale being transferred to sanctioned entities.

Although this warning is not addressed to financial institutions in the Bailiwick, it is drawn to your attention on the basis that the Bailiwick authorities are likely to take a similar approach to that expressed by the EU when considering the issue of circumvention of restrictive measures in the Bailiwick.



All businesses must familiarise themselves with the legislation and check whether they have any kind of relationship that may relate to prohibited activity or to attempts to circumvent the restrictions. Any findings must be reported to the Policy Council immediately. The information referred to above is required by the Policy Council in the exercise of its powers under the Schedule to each of the Ordinances listed above.

Any information or queries should be sent to with the subject line "Russian Federation".

Further information on sanctions measures and related issues including licences is available on the States of Guernsey website at