UK legal-services licence covers 26 autonomous sanctions regimes

LONDON, December 17, 2025 — The Office of Financial Sanctions Implementation’s amended legal-services general licence creates a common route for certain payments involving UK asset-freeze targets across 26 autonomous sanctions regimes.

The licence took effect Oct. 29, 2025, and runs through April 28, 2026. It was signed Oct. 22 and marked as amended Dec. 17, although the available material does not specify what changed in that amendment.

Subject to its conditions, the licence allows people, financial institutions and certain non-UK account providers to receive, make or process payments related to designated persons. It also permits designated persons to pay professional legal fees, counsel’s fees and related expenses for covered legal services.

The framework applies separate conditions to services based on obligations established before designation and those not based on prior obligations. Each part caps professional legal fees and counsel’s fees at £2 million per designated person, per law firm or directly instructed counsel, for the licence period. Where both parts apply, the combined ceiling is £4 million.

Permitted non-UK accounts are limited to supervised institutions in Canada, EU or European Free Trade Association member states, and the United States. Users must report specified payment information to HM Treasury within 14 days and retain records for at least six years.

The permissions do not cover payments to or for the benefit of people designated to implement UN sanctions obligations. For compliance teams and payment processors, that exclusion and the licence’s regime coverage are central to determining whether a legal-services payment falls within the framework.