Licensing

The UK Office of Financial Sanctions Implementation grants licences (exceptions) to some UK sanctions measures (including asset freezing prohibitions). The Sanctions Act providing the legal framework for licensing is here.

Guidance on UK licensing is as follows:

• Guidance on Exceptions and Licensing, Financial Sanctions General Guidance (December 2020)
• Guidance on Licences that allow activity prohibited by financial sanctions (1 January 2020)
• Counter-Terrorism Licensing Policy Paper (11 January 2021)

The application form for specific licences is here: OFSI Licence Application Form

The General Licences published so far are:

• General Licence INT/2020/059, which grants payment exemptions in relation to certain sea ports in Crimea (1 January 2021). Publication notice here.

• General Licence INT/2020/G1, which permits the Legal Aid Agency to make payments to solicitors representing people designated under counter-terrorism sanctions (11 January 2021).

Export control licences permit prohibited activity under trade sanctions and embargoes. For details see:

• Guidance on exporting controlled goods
• SPIRE (the UK online licensing system), the Open General Export Licence & Goods Checker and Guidance on how to apply for licences using SPIRE