Guernsey: record fine imposed for sanctions compliance failures

In 2025, authorities in Guernsey have recently imposed a significant financial penalty on ITI Trade Ltd, highlighting the increasingly strict enforcement of international sanctions compliance. The Guernsey Financial Services Commission (GFSC) fined the company £175,000, along with an additional £35,000 penalty imposed on its director, for serious compliance breaches.

The investigation revealed substantial weaknesses in the company’s compliance framework. ITI Trade Ltd was operating in a high-risk jurisdiction without an effective sanctions screening system, particularly with respect to Russian clients. No formal country or customer risk assessment had been conducted, and screening activities were outsourced to a Russian affiliated entity using processes deemed rudimentary and unreliable by the regulator.

This case reinforces a core principle of export control and sanctions compliance: regulatory responsibility cannot be outsourced. Even when operational or compliance tasks are delegated, the exporting or service-providing entity remains fully accountable for compliance with applicable sanctions regimes, including obligations related to end-users and services performed abroad.

The GFSC’s decision serves as a clear warning to financial and commercial operators engaged in international activities. It underscores the importance of implementing robust screening, due diligence and risk governance mechanisms that reflect the complexity of corporate structures and the sensitivity of certain jurisdictions. In an environment of expanding sanctions regimes and heightened regulatory scrutiny, compliance must be treated as a central element of corporate risk management rather than a transferable operational task.