New UK guidance on licensing legal services

OFSI has updated its general guidance on providing legal advice to designated persons (FAQs 3.4.1 and 3.4.2). The new guidance states that obtaining a licence before providing substantive legal services is encouraged rather than required, but that no payment for legal services by or on behalf of a designated person should be received before obtaining a licence (since that would be dealing with frozen funds or making funds available to or for the benefit of a designated person). OFSI also states that it encourages you to obtain a licence, for the legal fees you intend to charge, as soon as possible if you would like certainty on the fees and expenses you will be able to recover while the individual or entity remains subject to sanctions. Any unreasonable legal fees or expenses won’t be licensed for payment.