New UK legal services GL covering most UK sanctions regimes from 29 October 2025
22 October 2025
The UK has issued General Licence INT/2025/7323088, which now allows UK law firms, legal advisers, and counsel to receive payment from people and entities sanctioned under most UK sanctions regimes without a specific licence from OFSI – publication notice. The previous GL, which will expire at 23.59 UK time on 28 October 2025, extended only to the UK’s Russia and Belarus sanctions regimes. The new licence comes into effect on 29 October and expires on 28 April 2026. All UK GLs are on our UK Licensing page.
Key points:
- Most sanctions regimes are now covered by this GL. The complete list of regimes is listed in Annex 1 of the GL. The previous GL covered only the UK’s Russia and Belarus regimes.
- Law firms, legal advisors, counsel etc. may rely on this GL to receive fees and/or expenses as long as the conditions in Part A or Part B of the GL are met.
- The new GL does not permit payment directly or indirectly to or for the benefit of any person designated for the purpose of compliance with United Nations obligations. This means the GL cannot be used to make payments to people or entities designated under United Nations sanctions. This was not included in the previous GL because the UN does not have a Russia or Belarus sanctions regime.
- The new GL resets the legal fees and expenses caps as before.
- Any payments received under the new GL must be reported to OFSI within 14 days using OFSI’s online reporting form.
UK sanctions regimes not listed in Annex 1 of the new GL (which therefore still require a specific licence) are:
- Afghanistan
- Domestic and international counterterrorism
- Haiti
- Iraq; and
- ISIL and Al-Qaida.
