OFSI introduced a new Legal Services General Licence – INT/2025/6160920 – following the expiry of General Licence INT/2024/5334756 on 28 April 2025. It takes effect from 00:01 on 29 April 2025 to 23:59 on 28 October 2025.
This licence, issued under Regulation 64 of the <span class="news-text_italic-underline">Russia (Sanctions) (EU Exit) Regulations 2019</span> and Regulation 32 of the <span class="news-text_italic-underline">Republic of Belarus (Sanctions) (EU Exit) Regulations 2019</span>, allows UK legal firms or counsel to receive payments from individuals or entities designated under the Russia or Belarus sanctions regimes, without the need for a specific OFSI licence, provided the terms of the General Licence are met.
Key features of INT/2025/6160920 include:
- <span class="news-text_medium">Updated Caps for Legal Fees and Expenses:</span> The legal fees cap is set at £2,000,000 (including VAT), with expenses capped at 10% of legal fees, up to £200,000 (including VAT), for both Parts A and B of the General Licence.
- <span class="news-text_medium">Payment for Unpaid Legal Fees:</span> If a law firm, legal adviser, or counsel has not yet received payment for professional legal or counsel fees under the General Licence, they may receive up to £50,000 in expenses for each designated person, per law firm or counsel, during the term of the General Licence.
- <span class="news-text_medium">Amendment to Non-UK Bank Account Permission:</span> The non-UK bank account permission has been expanded to include counsel, enabling them to receive payments under the terms of the licence.
It is important to note that the General Licence does not authorise actions that the person carrying them out knows, or has reasonable grounds to suspect, will result in funds or resources being made available in breach of the Russia or Belarus Regulations or other relevant sanctions laws unless specifically permitted by the licence or another granted by HM Treasury.
Reporting and Record-Keeping Requirements
- <span class="news-text_medium">Reporting:</span> Any payments received under General Licence INT/2025/6160920 must be reported to HM Treasury within 14 days. Users must submit details and supporting evidence as specified in Part A or Part B of the licence. Reporting forms are available for download on the OFSI website.
- <span class="news-text_medium">Record-Keeping:</span> A minimum of 6 years of accurate, complete and readable records must be kept for any activities carried out under this licence, whether in paper or electronic format.
HM Treasury may vary, revoke or suspend this licence at any time.
