OFSI General Licences

The Office of Financial Sanctions Implementation (OFSI) of the HM Treasury has published a new General License (INT/2023/3744968) under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855) and Regulation 32 of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (SI 2019/600). The license permits financial institutions and payment service providers to make payments that would otherwise be prohibited by these regulations under regulations 11 through 15.
Specifically, the license allows financial institutions and payment service providers to – as quoted:
– receive payments from or on behalf of a DP;
– make payments (directly or indirectly) for or on behalf of a DP;
– make payments for the benefit of a DP; and
– process payments which relate to a DP
so long as these payments are for the purposes of the payment of legal services which the DP has requested (counsellor fees, legal fees). The general license only applies to those legal services that the DP has engaged in before it was sanctioned by OFSI and provided that certain prescribed thresholds are not exceeded (e.g. the fees do not exceed „£1,000,000 (including VAT where applicable) in total for the duration of this licence“).