General sanctions licence issued by OFSI in the UK to facilitate payment of legal fees
On 28 October 2022, the UK’s Office of Financial Sanctions Implementation (OFSI) issued General Licence INT/2022/2252300 (the OFSI Licence) to allow persons who have been designated to receive legal advice and representation.
The OFSI Licence allows UK legal firms and UK counsel who provided legal advice to a person designated under either the Russia or Belarus regime to be paid provided that the terms of the OFSI Licence are met. The licence distinguishes between legal fees in relation to ‘pre-designation’ work, and work started ‘post-designation’. Under the OFSI Licence it continues to be prohibited to make funds available to designated persons.
The OFSI Licence does not, for the time being at least, apply in the UK Overseas Territories such as Bermuda, the BVI, or the Cayman Islands.
OFSI’s blog posting on the OFSI Licence can be found here.