The new General Licence for Legal Services (INT/2025/7323088) issued by the Office of Financial Sanctions Implementation (“OFSI”) came into effect on 29 October 2025.
OFSI has updated this General Licence to expand its application to all UK Autonomous Sanctions Regimes (with the exception of the two Counter Terrorism regimes).
This is an important and long-awaited update which puts persons designated under the vast majority of UK Sanctions Regimes on equal footing in terms of being able to pay for legal services in the UK. Prior to today, any person designated under regimes other than the Russian and Belarussian regimes were forced to apply for a specific licence in order to do so – an often onerous and potentially expensive process with unpredictable wait times.
As a firm that has undertaken sanctions work for 25 years, representing clients under both geographic and thematic sanctions regimes, Carter-Ruck welcomes the positive impact this development will have on access to justice in the UK.
General Licence INT/2025/7323088 has also reset the fees and expenses caps for Parts A and B for the six-month period from 29 October 2025 to 28 April 2026, as has been the case with previous General Licences for Legal Services.
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