UK publishes FAQs on legal services general licence

24 October 2025

The UK Office of Financial Sanctions Implementation has issued 2 FAQs to clarify the scope of the legal services GL which is due to come into effect on 29 October 2025. The new GL now covers most UK autonomous sanctions regimes having previously only applied to the Russia and Belarus sanctions regimes (see Annex 1 of the GL for the list). FAQs 170 and 171 clarify:

• Law firms, legal advisors, counsel and providers of expenses (as defined in the GL) can rely on the GL to receive payment from persons designated under one of these regimes, as long as all the conditions of the licence are met.

• The GL does not permit payment to or for the benefit of any person designated under United Nations sanctions obligations.

• The GL permits fee payments to be sent from abroad and into a UK bank account or certain non-UK bank accounts (as set out in the GL), as long as all the conditions of the licence are met.

All UK GLs are on our Licensing page. See our UK Guidance page for OFSI’s FAQs and related guidance.