OFSI General Licence – INT/2023/3749168

The UK government has updated its license under the Counter-Terrorism (International Sanctions) (EU Exit) Regulations 2019 (“the CT2 Regulations 2019”) which permits otherwise prohibited (financial) transactions for the purpose of allowing the United Nations and other non-government organisations to provide humanitarian aid in connection with the Israel-Palestinian conflict. Specifically, the license permits the processing of any funds or other economic resources whenever necessary to support such aid, so long as the funds don’t stem from sanctioned individuals unless the funds are used for just such purpose.
The license further necessitates that any such activities must be reported to the Office of Financial Sanctions Implementation (OFSI) no later than 30 days of the expiration date of this license and should include details on the organization for which the fund transfer was originated, the type of activity supported, and the total value of the funds, resources, or goods processed under this license.
The latest update to the license includes the following:
– the Disasters Emergency Committee was added to the list of organizations that may provide humanitarian aid and that may be exempt from otherwise prohibited (financial) transactions;
– the definition of a „UK Funded Person“ was modified for clarification purposes;
– the geographical extent of this licence was also modified for clarification purposes; and
– the reporting obligations were updated to make clear that only „relevant persons“ – that is those organization benefiting from the license – have to report to OFSI.