The Office of Financial Sanctions Implementation (OFSI) of the HM Treasury has published a revised General License (INT/2022/2349952) under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855). In relation to agricultural commodity transactions, the license permits
(1) the provision of funds or economic resources to designated persons, exporters, and firms holding a license from the Department for International Trade (DIT license holder);
(2) the dealing with funds or economic resources and the processing of such on behalf of designated persons, exporters, and DIT license holders;
(3) the provision of insurance and reinsurance services as well as underwriting services to same persons; and
(4) the receiving of funds from same persons.
Commodity transactions thereby refer to all financial transactions relating to the export, sale, production, and / or transport of agricultural commodities, including the payment of related fees (e.g. banking fees) or payment of insurance premiums.
Additionally, and now new, the license permits the Grain and Feed Trade Association (GAFTA) to collect funds from designated persons in connection with „membership fees, costs deposits and arbitrator’s fees related to arbitrations regarding such contracts, training courses, and certification of laboratories for the testing of Agricultural Commodities which are traded under GAFTA contract terms and conditions“. Accordingly, financial institutions may process and deposit such funds in GAFTA accounts. Finally, insurance undertakings may provide indemnity insurance to GAFTA for commodity-related activities.
