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By Maya Lester KC & Michael O’Kane

UK Licensing

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UK Licensing

Introduction

Licences can be issued by UK licensing authorities to allow activity that would otherwise be prohibited by sanctions.

In relation to financial sanctions, the licensing authority is the UK Office of Financial Sanctions Implementation (OFSI), part of HM Treasury. For trade sanctions, the licensing authority is the Office for Trade Sanctions Implementation (OTSI), part of the Department for Business & Trade. Licences for the export/import of various goods are granted by the Import and Export Control Units, also part of the Department for Business & Trade. Licences can also be granted to allow certain transport related activity in respect of particular countries, by the Department for Transport.

Licences can be specific or general. A General Licence permits all parties to carry out specified activities otherwise prohibited by sanctions legislation without the need for a specific licence. A list of current and expired General Licences can be found at the end of this section.  Specific licences can be applied for by individuals and entities for particular activities on specific grounds set out in the relevant legislation, that are not covered by a general licence and would otherwise be prohibited.

 

Financial Sanctions

OFSI issues general licences and grants specific licences in relation to UK financial sanctions measures (including asset freezing prohibitions). The legal framework for licensing is set out in section 15 of the Sanctions and Money Laundering Act 2018 (SAMLA). Specific licences attach to the particular sanctions regime in question. For example, in relation to Russia, the specific licensing grounds are found in Schedule 5 to the Russia Regulations 2019.

Applications for specific licences should be made using the: OFSI Licence Application Form.

Guidance on OFSI licensing:

 

Trade Sanctions

3 licensing bodies administer licences to carry out activity under UK trade sanctions:

Body Responsible for Example
Office of Trade Sanctions Implementation (OTSI) Licensing relating to the provision of standalone services, including professional and business services UK incorporated company planning to provide services prohibited under sanctions
Import Controls and Sanctions Team Licensing for import of goods prohibited under UK import controls or sanctions Trader looking to import controlled goods, e.g. firearms or ammunition
Export Control Joint Unit (ECJU)

(see also Export Controls)

 Licensing for the export of goods, software & technology Trader looking to export military items and dual-use items on the UK’s Strategic Export Control List

Guidance on UK trade sanctions licensing for OTSI and the ECJU:

OTSI Guidance:

Export Control Licences:

Export control licences permit prohibited activity under trade sanctions and embargoes.

A list of UK general export licences is here, including:

UK general licences include:

General Trade Licence Guidance:

For further details see:

 

Transport Sanctions

Apply for a transport sanctions licence.

Guidance:

Department for Transport Guidance

 

General Licences

OFSI General Licences

Current General Licences:

  • General Licence INT/2021/554388, “Emergency Payment(s) Directly or via an Intermediary to Belaeronavigatsia for Air Traffic Services” (Notice), which authorises emergency payments to/for the benefit of Belaeronavigatsia (19 July 2021)
  • General Licence INT/2022/1280976, “Russia: Regulatory Authorities – Prudential Supervision or Financial Stability” (Notice), which authorises financial authorities involved in the regulation of UK financial services to do anything with regard to VTB Capital and its UK subsidiaries related to prudential supervision, or protecting, maintaining or enhancing the financial stability of the UK (1 March 2022).
  • General Licence INT/2022/1280876, “Russian Banks – UK subsidiaries – Basic needs, routine holding and maintenance and the payment of legal fees” (Notice), which authorises certain UK, EU and Guernsey subsidiaries of Russian banks (VTB and Sberbank) to make payment for its basic needs, reasonable fees or service charges arising from routine holding and maintenance of its frozen funds and economic resources and reasonable professional fees for the provision of legal services. People / entities may also make / receive / process payments in connection with Insolvency Proceedings related to the subsidiaries (1 March 2022, as amended).
  • General Licence INT/2022/1322576, “Provision of navigational data to civilian aircrafts for flight safety” (Notice), which indefinitely authorises a flight data provider to make payment directly or via a relevant institution to Belaeronavigatsia for aeronautical information publication data (9 March 2022).
  • General Licence INT/2022/1679676, “Law Enforcement and Regulatory Authorities Asset Recovery” (Notice), issued under the Russia and Global Anti-Corruption sanctions regimes. Subject to certain conditions, indefinitely authorises the an officer of the Financial Conduct Authority (FCA) (or another organisation authorised by HM Treasury) to carry out their duties and actions necessary to comply with specified orders, negotiated settlements, or approved deferred prosecution agreements (27 April 2022).
  • General Licence INT/2022/1710676, “Continuation of Business of Evraz Plc’s North American Subsidiaries” (Notice), which authorises:
    • The continuation of business operations involving Evraz North America plc, Evraz Inc. NA and Evraz Inc. NA – Canada, including:
      • payments to or from these subsidiaries under any obligations or contracts;
      • payments to or from any third party under any obligations or contracts; and
      • receipt of payments made by these subsidiaries for audit services;
    • Evraz North America plc to pay for audit services; and
    • Relevant UK Institutions to process the payments outlined above (5 May 2022, amended 18 August 2022).
  • General Licence INT/2022/1678476, “Amsterdam Trade Bank N.V – winding down, basic needs and insolvency related payments” (Notice), which authorises:
    • Amsterdam Trade Bank N.V (ATB) to make payment for its basic needs including: payment of remuneration, allowances or pensions of employees; payment of tax; payments to suppliers of goods and services.
    • Any person/entity to make, receive or process any payments, or take any other action, in connection with any insolvency proceedings relating to ATB, whether prior to or after the commencement of such proceedings, including, without limitation, an insolvency practitioner for the purposes of his or her functions under or in connection with insolvency proceedings.
    • A person/entity (other than ATB or a subsidiary) to wind down any transactions involving ATB or a subsidiary to which it is a party, including the closing out of any positions and the restructuring of loans or other debt. A person/entity, Relevant Institution, ATB or a subsidiary may carry out any activity reasonably necessary to effect this (12 May 2022).
  • General Licence INT/2022/1839676, “Russian Travel for UK Nationals” (Notice), which authorises:
    • A UK national or entity to purchase tickets from Aeroflot, Rossiya Airlines, Ural Airlines or Russian Railways, or any subsidiary of these, for flights or rail journeys originating in, or within Russia; and
    • A UK national or entity, Relevant Institution, Aeroflot, Rossiya Airlines, Ural Airlines or Russian Railways, or any subsidiary of these entities, to carry out any activity reasonably necessary to effect the purchase of tickets for flights or rail journeys in accordance with the above (23 May 2022).
  • General Licence INT/2022/1834876, “Russia Designated Persons – Charities and Interim Managers and trustees” (Notice), which authorises an Interim Manager and/or trustee of a charity linked to a person/entity listed on the UK’s Russia sanctions list to undertake various activities in relation to the charity (30 May 2022).
  • General Licence INT/2022/1875276, “Continuation of Business and Basic Needs for Telecommunications Services and News Media Services” (Notice), which authorises transactions related to the continuation of business operations involving ZAO TransTeleCom Company and News Media Services (30 May 2022).
  • General Licence INT/2022/1947936, “Humanitarian Activity”, which authorises an approved list of organisations (including the UN, ICRC, Red Cross and Red Crescent, Médecins Sans Frontières, members of the UK Disasters Emergency Committee and others) to:
    • perform activities to ensure the timely delivery of humanitarian assistance activity in relation to the conflict in Ukraine and non-government controlled Ukrainian territory; or
    • carry out other activities that support basic human needs in relation to the conflict in Ukraine and non-government controlled Ukrainian territory (7 July 2022).
  • General Licence INT/2022/2085212, “Mongolia Energy Payments” (Notice), which authorises a person / entity to make payments to Credit Bank of Moscow, Gazprombank, Sberbank or Rosbank PJSC, or a subsidiary of any of these, for the purpose of making energy available for use in Mongolia (15 August 2022).
  • General Licence INT/2022/1845976, “Crown Servants, Contractors & their Family Members” (Notice). Where Crown immunity does not apply to activities by reason of non-application of the Russia (Sanctions) (EU Exit) Regulations 2019 to the Crown, the GL authorises:
    • a Crown Servant, Contractor, Family Member or Visiting Family Member to carry out activities in their personal capacity in Russia, which would otherwise be prohibited by regulations 11-15 and 17A of the Russia Regulations; and
    • in the case of a Visiting Family Member, the permission above extends only to those activities which arise as a result of their being in Russia to visit the household of a Crown Servant or Contractor (16 August 2022).
  • General Licence INT/2022/2009156, “Permitted Payments to UK Insurance Companies” (Notice), under 19 of its autonomous sanctions regimes. It indefinitely authorises (subject to reporting and record-keeping requirements):
    • UK designated people / entities to make ‘Permitted Payments’ (insurance premiums, reinsurance premiums and broker commissions relating to the provision of Buildings Insurance, Terrorism Cover, Property Owners’ Liability Insurance, Claims Preparation Costs Insurance and Engineering insurance provided to UK properties) to UK insurers from a frozen UK bank account;
    • UK insurers to receive Permitted Payments;
    • UK insurers to make ‘Return Payments’ to frozen UK bank accounts (for the payment of funds due as a result of a claim made pursuant to the Permitted Payments, or as a result of an overpayment); and
    • UK designated people / entities to receive Return Payments from UK Insurers into a frozen UK bank account (22 July 2022, amended 17 August 2022).
  • General Licence INT/2022/2104808, “Bank Fees” (Notice), which indefinitely authorises a Bank to take the payment of Service Fees from accounts frozen under the Russia Regulations arising from the routine holding or maintenance of those accounts. This permits the payment of Service Fee arrears but does not permit the payment to banks designated under Russia sanctions. Should payments of Service Fees result in tax liability, payment may be made to settle these and HMRC may receive such payments. Records of activity purported to have been permitted under this licence must be kept for a minimum of 6 years (22 August 2022).
  • General Licence INT/2022/2349952, “Transactions Related to Agricultural Commodities Including the Provision of Insurance and Other Services” (Notice), which allows, subject to certain conditions, transactions related to agricultural commodities including the provision of insurance and other services (4 November 2022)
  • General Licence INT/2022/2300292, “Payment to Utility Companies for Gas and / or Electricity” (Notice), which authorises the payment of utility companies for gas and electricity supplies by UK designated people or entities that own or rent UK properties (17 November 2022).
  • General Licence INT/2022/2470056, “Correspondent banking and payment processing” (Notice), indefinitely authorises Relevant Institutions to process, clear or send payments from any person / entity in connection with activities that would otherwise breach Russia regulation 46Z9C, subject to conditions (5 December 2022).
  • General Licence INT/2023/2589788, “Wind down of Trust Services provided to Designated Persons” (Notice), permits the wind down of Trust Services provided to Designated Persons otherwise prohibited by Regulation 18C of the Russia Regulations.
  • General Licence INT/2023/2824812, “Bond amendments and restructurings for non-Designated Persons” (Notice), pursuant to which, an Issuer which considers that it has or may have Bondholders who are Designated Persons may effect the terms of any Bond restructuring or amendments agreed between itself and its Bondholders, provided that the conditions of the General Licence are met.
  • General Licence INT/2023/3074680, “Oil Price Cap: Trading in Derivatives and Futures”, which authorises trade in Derivatives and Futures in connection with activities which would otherwise contravene regulation 46Z9C of the Russia Regulations, and associated payments/provisions of brokering services (14 June 2023).
  • General Licence INT/2023/3263556, “GTLK Companies and their Subsidiaries – Insolvency related payments and activities”, which authorises payments concerning insolvency proceedings of GTLK and its subsidiaries (1 August 2023).
  • General Licence INT/2023/3179120, “Payment to Water Companies for Water & Sewage” (Notice), permits UK designated individuals and entities to pay water companies for water and sewage services.
  • General Licence INT/2024/4423849, “Oil Price Cap” (Notice), which permits the supply or delivery by ship of Russian crude oil and oil products, as well as provision of associated services, so long as the price paid for Russian oil or oil products is at or below the price cap.
  • General Licence INT/2024/4398024, “Court Funds Office Payments” (Notice), which allows Persons who owe monies to a designated person as a result of a Court Order to pay these to the Court Funds Office and for the Court Funds Office to receive these payments.
  • General Licence INT/2024/4761108,”Personal Remittances” (Notice), permits non-DPs to make use of the retail banking services of a designated Credit or Financial Institution for their personal use up to £50,000.
  • General Licence INT/2024/5028385, “East-West United Bank – Insolvency related payments and activities” (Notice), allows payments and other permitted activities to take place in relation to the insolvency proceedings associated with East-West United Bank (9 August 2024).
  • General Licence INT/2024/5394840, “Correspondent Banking – 2022 Blocked Payments” (Notice), permits relevant institutions to process payments made in 2022 from or through a designated credit or financial institution, provided that the sender and recipient are not designated persons (7 November 2024).
  • General licence INT/2025/5635700, “Russian Oil Exempt Projects” (Notice), allows for the continuation of business operations with Gazpromneft-Sakhalin LLC (and any entity owned or controlled, directly or indirectly, by it) to the extent they are in relation to Sakhalin-2 (10 January 2025).
  • General licence INT/2025/5632740 “Interim Basic Necessities for Designated Persons” (Notice),  allows Persons to make funds available to or for the benefit of a UK DP up to the Permitted Maximum in each of the two Months following the date of the UK DP’s designation for the purpose of the UK DP making payments for food and beverages, medicines and medical products, and personal and household products (14 January 2025).
  • General Licence INT/2025/5810196 “Syria humanitarian activity” (Notice), which allows for payments to be made in respect of relevant humanitarian assistance activities (12 February 2025)
  • General Licence INT/2025/5855272 “Membership Fees for International Organisations” (Notice), which allows International Organisations to receive Permitted Payments transferred from an account held with Gazprombank (21 February 2025)
  • General Licence INT/2025/5886860 “Petrol station payments for United Kingdom nationals in Kyrgyzstan and Tajikistan” (Notice), which allows UK nationals to purchase petrol from Gazpromneft (or its subsidiaries) at any petrol station in Kyrgyzstan and Tajikistan that is either owned by Gazpromneft or sells its petrol, provided that the petrol is for that UK national’s personal vehicle (14 March 2025)
  • General Licence INT/2025/5787748 “Arbitration Costs” (Notice), which applies to the Russia & Belarus regimes and authorises designated people and entities to make payments to Arbitration Associations and Arbitrators to cover fees and expenses for their arbitration services; and to representatives (or legal representatives) of designated persons to cover Arbitration Costs (31 March 2025)
  • General Licence INT/2025/6135848, “Integration of Credit Suisse Group AG and UBS Group AG” (Notice), which allows the transfer of assets and liabilities as part of the integration of Credit Suisse Group AG into UBS Group AG (28 April 2025)
  • General Licence INT/2025/6160920, “Legal Fees (Russia & Belarus)” (Notice), permits a UK legal firm or UK counsel who has provided legal advice to a person designated under either the Russia or Belarus regime to receive payment from that designated person without an OFSI specific licence (29 April 2025)
  • General Licence INT/2025/6275812, ” Wind Down of Positions Involving St Petersburg Currency Exchange and Non-bank Credit Organization Joint-Stock Company Petersburg Settlement Center” (Notice), which permits wind down transactions down involving JSC SPCEX and/or JSC PSC (20 May 2025)

 

Expired and Revoked General Licences

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