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Cyber-Crime

Please be advised that an asset freeze and travel ban have been imposed on six people and three entities under the EU's cyber sanctions regime.

These are the first designations to be made under the regime. Those listed are said to be responsible for or involved in cyber-attacks originating outside the EU with significant or potentially significant effect, which constitute an external threat to the EU or its member states, third states or international organisations

The six people who have been designated are Gao Qiang, Zhang Shilong, Alexey Valeryevich Minin, Aleksei Sergeyvich Morenets, Evgenii Mikhaylovich Serebriakov, and Oleg Mikhaylovich Sotnikov.

The three entities that have been designated are Tianjin Huaying Haitai Science and Technology Development Co. Ltd (Huaying Haitai), Chosun Expo, and the Main Centre for Special Technologies (GTsST) of the Main Directorate of the General Staff of the Armed Forces of the Russian Federation (GU/GRU).

The EU regulation can be found here: Council Implementing Regulation (EU) 2020/1125. It is implemented within the Bailiwick by the Cyber-Crime (Restrictive Measures) (Bailiwick of Guernsey) Regulations, 2019.

 

MEASURES WHICH SHOULD BE TAKEN

 

All businesses must check whether they maintain any accounts or otherwise have any kind of relationship with the persons 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. They must also 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.