OFSI General Licence INT/2023/3626884

On October 19, 2023, the HM Treasury’s Office of Financial Sanctions Implementation (OFSI) published a Publication Notice to inform that is has made various changes to its General Licence INT/2023/3626884 which permits financial institutions and payment service providers to
– process payments of UK sanctioned individuals (DPs) or payments made by another person on behalf of such DP for the purpose of making payments to the Companies House for the filing of annual returns (confirmation statement) or the payment of late fees; and
– process payments for the purpose of receiving same payments from the Companies House.
While some modifications are technical in nature (change in wording) to improve clarity, others extend the application of the license to Regulation 17A of the Russia (Sanctions) (EU Exit) Regulations 2019 which prohibits UK credit or financial institutions to maintain correspondent banking relationships with other designated institutions, with designated entities, persons, and bodies. In other words, such payments to the Companies House may be processed, even if the payments are made via the processing of payments involving sanctioned institutions.