This news release is issued to publicise the addition of 8 entries under the Global Anti-Corruption sanctions regime.
The Global Anti-Corruption Sanctions Regulations 2021 have effect in the Isle of Man by the Sanctions (Implementation of UK Sanctions) Regulations 2024 ('the Regulations'), which are made under the Sanctions Act 2024. These Regulations impose financial sanctions for the purpose of preventing and combatting serious corruption from a country outside the Isle of Man.
Those persons who are designated under this regime are included on the UK sanctions list.
Types of sanctions applicable under this regime:
- Asset freeze
- Immigration
On 21 November, the Foreign, Commonwealth and Development Office updated the UK sanctions list. This list provides details of those designated under sanctions legislation.
Additions
Eight entries have been added to the Consolidated List and are now subject to an asset freeze.
Individuals
- DOS SANTOS, Isabel
DOB: 20/04/1973. POB: Baku, Azerbaijan Nationality: Angola Other Information: (UK Sanctions List Ref): GAC0050. (UK Statement of Reasons): Isabel DOS SANTOS is an involved person within the meaning of the Global Anti-Corruption Regulations 2021 on the basis of the following grounds: DOS SANTOS is or has been involved in (1) being responsible for or engaging in serious corruption; (2) profiting financially or obtaining any other benefit from serious corruption. Specifically, DOS SANTOS, whilst head of Angolan state oil firm Sonangol, misappropriated more than 50 million GBP for her own financial benefit and, whilst director of the Angolan telecoms company Unitel SA, misappropriated more than 300 million GBP for her own financial benefit. (Gender): Female Listed on: 21/11/2024 UK Sanctions List Date Designated: 21/11/2024 Last Updated: 21/11/2024 Group ID: 16694 - FIRTASH, Dmitry Vasylovych
DOB: 02/05/1965. POB: Ternopil Oblast, Ukraine a.k.a: (1) FIRTASH, Dimitry (2) FIRTASH, Dmytro Nationality: Ukraine Address: Gloriettegasse 10, Wien, Austria, 1130. Other Information: (UK Sanctions List Ref): GAC0055. (UK Statement of Reasons): Dmitry FIRTASH is an involved person within the meaning of the Global Anti-Corruption Sanctions Regulations 2021 on the basis of the following grounds: (1) FIRTASH is or has been involved in being responsible for or engaging in serious corruption. Specifically, FIRTASH has been involved in the bribing of public officials to obtain mining licenses, and FIRTASH has been involved in the misappropriation of property from the gas transport network of Ukraine. (Gender): Male Listed on: 21/11/2024 UK Sanctions List Date Designated: 21/11/2024 Last Updated: 21/11/2024 Group ID: 16699 - FIRTASH, Lada Pavlovna
DOB: 26/06/1972. POB: Kashira, Russia Nationality: (1) Cyprus (2) Russia (3) Ukraine Address: 8 Cottage Place, London, United Kingdom, SW3 2BE. Other Information: (UK Sanctions List Ref): GAC0056. (UK Statement of Reasons): Lada FIRTASH is an involved person within the meaning of the Global Anti-Corruption Sanctions Regulations 2021 on the basis of the following grounds: (1) FIRTASH is or has been involved in profiting financially or obtaining any other benefit from serious corruption. Specifically, FIRTASH has profited financially from the corruption of her husband, Dmitry FIRTASH; and (2) FIRTASH is associated with a person who is or has been involved in serious corruption, namely her husband Dmitry FIRTASH. (Gender): Female Listed on: 21/11/2024 UK Sanctions List Date Designated: 21/11/2024 Last Updated: 21/11/2024 Group ID: 16700
- GORBUNENKO, Denis Vladimirovich
DOB: 09/12/1973. POB: Donetsk Oblast, Ukraine a.k.a: (1) GORBUNENKO, Denis, Vlodymyrovich (2) HORBUNENKO, Denis Nationality: Ukraine Other Information: (UK Sanctions List Ref): GAC0057. (UK Statement of Reasons): Denis GORBUNENKO is an involved person within the meaning of the Global Anti-Corruption Sanctions Regulations 2021 on the basis of the following grounds: (1) Denis GORBUNENKO has been involved in engaging in serious corruption. Specifically, Denis GORBUNENKO engaged in serious corruption for the benefit of Dmitry FIRTASH while in a controlling position at Rodovid Bank; (2) GORBUNENKO is or has been involved in transferring or converting, or facilitating the transfer or conversion of, any profit or proceeds from serious corruption. Specifically, GORBUNENKO has been involved in facilitating the transfer or conversion of the profit or proceeds of Dmitry FIRTASH's serious corruption; and (3) GORBUNENKO is acting on behalf of a person who is or has been involved in serious corruption, namely Dmitry FIRTASH. (Gender): Male Listed on: 21/11/2024 UK Sanctions List Date Designated: 21/11/2024 Last Updated: 21/11/2024 Group ID: 16701 - LEMBERGA, Liga
DOB: --/07/1976. POB: Latvia Nationality: Latvia Other Information: (UK Sanctions List Ref): GAC0054. (UK Statement of Reasons): Liga LEMBERGA is an involved person under the Global Anti-Corruption Sanctions Regulations 2021 on the basis of the following grounds: LEMBERGA is or has been involved in (1) facilitating or providing support for serious corruption; (2) profiting financially or obtaining any other benefit from serious corruption. Specifically, LEMBERGA has been involved in the bribery and misappropriation of her father, Aivars Lembergs. (Gender): Female Listed on: 21/11/2024 UK Sanctions List Date Designated: 21/11/2024 Last Updated: 21/11/2024 Group ID: 16698 - LEMBERGS, Aivars
DOB: 26/09/1953. POB: Jēkabpils, Latvia Nationality: Latvia Address: Ventspils, Latvia. Other Information: (UK Sanctions List Ref): GAC0053. (UK Statement of Reasons): Aivars LEMBERGS is an involved person under the Global Anti-Corruption Sanctions Regulations 2021 on the basis of the following grounds: LEMBERGS is or has been involved in (1) being responsible for or engaging in serious corruption Specifically, LEMBERGS, whilst mayor of Ventspils, has been responsible for or has engaged in serious corruption by way of bribery and the misappropriation of property. (Gender): Male Listed on: 21/11/2024 UK Sanctions List Date Designated: 21/11/2024 Last Updated: 21/11/2024 Group ID: 16697
- OLIVEIRA, Paula Cristina Fidalgo Carvalho Das Neves
Nationality: (1) Angola (2) Portugal Other Information: (UK Sanctions List Ref): GAC0052. (UK Statement of Reasons): Paula OLIVEIRA is an involved person within the meaning of the Global Anti-Corruption Sanctions Regulations 2021 on the basis of the following grounds: OLIVEIRA is or has been involved in (1) providing support for or facilitating serious corruption; or (2) profiting financially or obtaining any other benefit from serious corruption; or (3) in transferring or converting, or facilitating the transfer or conversion of, the profits or proceeds from serious corruption. Specifically, OLIVERIA has been involved in the misappropriation of property by Isabel DOS SANTOS from the Angolan state oil firm Sonangol. Listed on: 21/11/2024 UK Sanctions List Date Designated: 21/11/2024 Last Updated: 21/11/2024 Group ID: 16696 - RAIKUNDALIA, Sarju
Nationality: Portugal Address: United Arab Emirates. Other Information: (UK Sanctions List Ref): GAC0051. (UK Statement of Reasons): Sarju RAIKUNDALIA is an involved person within the meaning of the Global Anti-Corruption Sanctions Regulations 2021 on the basis of the following grounds: RAIKUNDALIA is or has been involved in (1) being responsible for or engaging in serious corruption; (2) providing support for or facilitating serious corruption; (3) transferring or converting or facilitating the transfer or conversion of, the profits or proceeds from serious corruption; (4) profiting financially or obtaining any other benefit from serious corruption. Specifically, RAIKUNDALIA has been involved in the misappropriation of property by Isabel Dos Santos from the Angolan state oil firm Sonangol. (Gender): Male Listed on: 21/11/2024 UK Sanctions List Date Designated: 21/11/2024 Last Updated: 21/11/2024 Group ID: 16695
What you must do
If you suspect a person or entity is a match to a person or entity included in the UK Sanctions List, and you hold or otherwise deal with funds or economic resources of that person:
- You must freeze the assets immediately
- You must review the information you hold for that person against the UK Sanctions List to ensure you do not have a false positive identification
- Do not deal with those assets or make them available to, or for the benefit of the designated person unless:
- You have a legal exemption
- You have a licence
- You must report the frozen assets to the FIU.
If you have a suspicion or knowledge that there has been a breach of sanctions law, or any attempted transactions that you have blocked, report your suspicions to the FIU.
Failure to comply with financial and trade sanctions legislation or to attempting to circumvent its provisions is a criminal offence.
Where a relevant institution has already reported details of accounts, other funds or economic resources held frozen for the designated person, you are not required to report these details again.
Note: determining if a customer is on the UK Sanctions List includes whether any corporate entity is owned or controlled, directly or indirectly, by a person on the UK Sanctions List.
Further guidance on false positives and delistings and what to do can be found in the Financial Sanctions General Guidance page.
Further Information
Further details on the UN measures in respect of Global Anti-Corruption sanctions can be found on the relevant UN Sanctions Committee webpage.
Further information on the sanctions regime related to Global Anti-Corruption and other sanctions related guidance can be found on the Sanctions and Export Control website on the Sanctions Guidance page.
Contact details for enquiries
If you require any further information or guidance, please contact the Sanctions Team on:
Telephone: +44 1624 648109
Email: sanctions@gov.im
Please note: We are unable to provide legal advice. You may need to seek independent legal advice.
