BVI's General Licences overview on Oil price pap and legal services
16 Apr 2026
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The British Virgin Islands Financial Services Commission (BVI FSC) published details of General Licences No. 12 (2026) and No. 11 (2025), issued under the authority of the Governor. These licences outline specific permissions and conditions for activities related to sanctions compliance, including the supply of Russian oil under price cap regulations and the payment of legal fees for designated persons. Below is a summary of their key provisions:
Summary of General Licences No. 12 (2026) and No. 11 (2025)
General Licence No. 12 (2026) - Oil price cap
Issued on 30 January 2026, this licence permits the supply, delivery, and associated services for Russian oil and oil products, provided the price cap terms are met. Key provisions include:
- Scope: Allows transactions involving Russian oil by ship between third countries, provided the unit price is at or below the specified price cap.
- Conditions: Tiered service providers (Tier 1, 2, 3A, 3B) must adhere to strict attestation and reporting requirements, ensuring compliance with price caps.
- Reporting: Tier 1 providers must report contracts to the Attorney General within 40 days, while Tier 2 and Tier 3 providers have 60 days to confirm compliance or withdraw services.
- Record-Keeping: All involved parties must maintain detailed records for six years.
- Exclusions: The licence does not permit the import of Russian oil into the Virgin Islands or transactions with designated persons or specified ships.
General Licence No. 11 (2025) - Payment of legal fees
Issued on 3 November 2025, this licence allows payments for reasonable professional legal fees and expenses for designated persons under sanctions. Key provisions include:
- Scope: Covers legal services provided by Virgin Islands legal practitioners, including advice and court representation, except for defamation claims.
- Payment limits: Professional legal fees are capped at US$2.4 million per practitioner, with expenses limited to 10 per cent of fees or US$240,000, whichever is lower.
- Conditions: Payments must relate to obligations entered into before the designation of the individual or entity.
- Reporting: Legal practitioners must report payments to the Attorney General within seven days, including detailed documentation of the services and payments.
- Record-keeping: Practitioners must retain records for six years.
- Exclusions: Payments cannot benefit persons designated under United Nations obligations.
These licences aim to balance compliance with international sanctions while facilitating specific permissible activities.
BVI’s General Licences can be found here
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