The Online Trade Sanctions Interface (“<span class="news-text_medium">OTSI</span>”) is officially live, offering a streamlined application process for trade services sanctions licences. Moving forwards, OTSI will handle the processing of all new applications for licences to provide sanctioned trade services.
OTSI’s introduction marks a significant development in the distribution of responsibilities between the three licensing bodies within the Department for Business and Trade (“<span class="news-text_medium">DBT</span>”).
Applicants must provide a clear definition of the services intended for licensing, demonstrating how these correspond with one or more categories of prohibited services under relevant sanctions regulations. Applications should reference these regulations carefully.
Applicants must also explain how the provision of these services would remain in line with the purposes of the sanctions. Specific activities, referred to as licensing ‘considerations’ or ‘grounds’, likely qualify for licences. If an application is made under these pre-defined grounds, it is important to show how the services fall within these considerations. Applications may also be made for services that do not fit within these grounds, provided they are consistent with the broader purpose of the sanctions.
A comprehensive list of pre-defined licensing grounds is available in the statutory guidance for each sanctions regime. For professional and business services supplied under the UK Russia Regulations, grounds include:
Legal advisory services may qualify for a licence if the relevant activity meets the licensing ground applicable under UK sanctions.
UK sanctions regulations apply to all individuals and businesses in the UK, as well as UK nationals and businesses operating abroad, under what is termed a “UK nexus”. A licence is not required to provide services that are either not prohibited by sanctions regulations or covered by an exception.
A licence may provide authorisation for:
Third parties, such as legal advisers, may apply on behalf of businesses or individuals by uploading a letter of instruction.
A new licence application is required if renewal is needed or if there are changes to the details of the licence, such as the scope of services or parties involved.
The updated gov.uk pages reflecting OTSI’s new licensing responsibilities can be accessed for various sanctions regimes, including:
For more details, visit the OTSI online licence application service.
