The National Coordinator for Anti-Money Laundering and the Combatting of Terrorist Financing has published a Newsletter in relation to the various international sanctions imposed on the Russian Federation following the invasion of Ukraine.
Real estate agents and letting agents (REAs) and High value Goods Dealers (HVGDs) in Gibraltar should note the applicability of these recent UK and EU sanctions in Gibraltar and take necessary steps to ensure that they comply with the requirements of the Sanctions Act 2019.
In conjunction with this the OFT has taken the opportunity to update its sample customer due diligence (CDD) forms for REAs and HVGDs. The forms now contain relevant sections to record the carrying out of sanctions screening. These forms can be found in the 'AML/CFT' and 'Documents' sections of the OFT's website. The CDD forms need not be adopted by regulated entities and are only provided to assist regulated entities to understand their CDD obligations.
The OFT also wishes to remind its regulated entities that in February the OFT issued updated Guidance Notes for REAs and HVGDs. Section 8 of both Guidance Notes contain information about targeted financial sanctions and regulated entities' obligations in relation thereto.