OFSI reissues its legal services licence with a wider expenses definition

The UK's Office of Financial Sanctions Implementation issued a new general licence that lets UK law firms and counsel be paid by sanctioned clients without a specific licence, with a wider definition of expenses, OFSI said in a publication notice.

General Licence INT/2026/11112108 took effect at 00:01 on 29 October, after its predecessor INT/2026/9512597 expired on 28 October, and runs to 23:59 on 28 April 2027, the notice says. It covers most UK autonomous sanctions regimes, listed in an annex that includes the Belarus, Democratic Republic of the Congo, global anti-corruption and global human rights regulations, according to the licence.

The first of the changes OFSI lists is to expenses. The licence now defines them as any fees or expenses associated with the legal services, including payments to other legal professionals instructed by the law firm or counsel for third-party legal assistance. OFSI also replaced "payable" with "paid" in the permissions that cap expenses at 10 per cent of the fees, and rewrote paragraph 5 so that payments may cover legal services that are still being provided, not only those already provided, to a designated person or another in the same group.

The financial limits are set per law firm or per counsel instructed directly. Where work began before a client was designated and continued after, combined fees under both parts of the licence may not exceed £4m, and expenses may not exceed the lower of 10 per cent of fees paid or £400,000. For work under Part B, which covers legal services not based on a prior obligation, hourly rates are capped by grade and location. For the most senior grade of fee earner, with more than eight years' experience, the caps excluding VAT are £896 in the London 1 band, £653 in London 2, £494 in London 3, £457 in National 1 and £446 in National 2, and counsel may charge up to £1,500 an hour including VAT.

The reporting period is aligned with OFSI's other general licences: instead of reporting within 14 days of each payment, anyone who has used the licence to receive payment must report to HM Treasury within 14 days of the end of each calendar month, and records must be kept for at least six years. The publication notice adds that the licence does not authorise any act that the person knows, or has reasonable grounds to suspect, would breach the regimes.

The licence is published on GOV.UK. It matters to firms in London acting for designated persons from emerging markets, whose sanctions exposure EM Governance Review tracks in its Sanctions and Enforcement Ledger; the EU's own measures are set out in our explainer on its 21st package.