General licence – INT/2022/2252300
OFSI has the power to issue General Licences for country sanctions regimes under regulations made under the Sanctions and Anti-Money Laundering Act 2018 (“the Sanctions Act”). On [28] October 2022, OFSI issued General Licence INT/2022/2252300 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”) and Regulation 32 of the
Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (“the Belarus Regulations”) which, subject to certain conditions, allows payments to be made for legal professional fees and expenses associated with the provision of legal services. Any persons intending to use General Licence INT/2022/2252300 should consult the copy of the Licence on this page for full details of the permissions and usage requirements.
For the purposes of General Licence INT/2022/2252300 a Designated Person (DP) means any individual or body of persons (corporate or unincorporate) designated under regulation 5 of the Russia Regulations or the Belarus Regulations and/ or any individual or body of persons (corporate or unincorporate) owned or controlled by that designated person as determined under the criteria set out in the Russia Regulations or the Belarus Regulations (in particular regulation 7 and Schedule
1 to each of those Regulations)
Economic resources mean assets of every kind, whether tangible or intangible, movable or
immovable, which are not funds but can be used to obtain funds, goods, or services as defined in
section 60(2) of the Sanctions and Anti-Money Laundering Act 2018).
Funds carries the same meaning as in section 60(1) of SAMLA and means financial assets and
benefits of every kind, including (but not limited to) —
a) Cash, cheques, claims on money, drafts, money orders and other payment instruments;
b) Deposits, balances on accounts, debts and debt obligations;
c) Publicly and privately traded securities and debt instruments, including stocks and shares,certificates representing securities, bonds, notes, warrants, debentures and derivative products;
d) Interest, dividends and other income on or value accruing from or generated by assets;
e) Credit, rights of set-off, guarantees, performance bonds and other financial commitments;
f) Letters of credit, bills of lading and bills of sale;
g) Documents providing evidence of an interest in funds or financial resources;
h) Any other instrument of export financing.
A Person, as defined in section 9(5) of the Sanctions and Anti-Money Laundering Act 2018, includes a body of persons corporate or unincorporate but does not include a DP.
A relevant institution means a Person that has permission under Part 4A of the Financial Services and Markets Act 2000 (permission to carry on regulated activity);
a Person that is authorised or registered under Part 2 of the Payment Services Regulations (SI 2017/752); a Person that is authorised or registered under Part 2 of the Electronic Money Regulations (SI 2011/99); or a Person that is an operator of a recognised payment system (or that is a service provider in relation to recognised payment systems) for the purposes of Part 5 of the Banking Act 2009.
Under General Licence INT/2022/2252300, provided that one of the sets of conditions in one of parts A or B of the General Licence are complied with in full, any Person or Relevant Institution may receive payments from a DP; make payments (directly or indirectly) for or on behalf of a DP; make payments for the benefit of a DP; process payments which relate to a DP; and any Person or
Relevant Institution may carry out any other act which is reasonably necessary to give effect to this.
General
The permissions in General Licence INT/2022/2252300 do not authorise any act which the person carrying out the act knows, or has reasonable grounds for suspecting, will result in funds or economic resources being dealt with or made available in breach of the Russia Regulations, the Belarus Regulations, or any other regulations made under the Sanctions and Anti-Money Laundering
Act 2018 save as specifically permitted under this or other licences granted by HM Treasury. General Licence INT/2022/2252300 takes effect from 28 October 2022 and expires on 27 April 2023 and may be varied, revoked or suspended by HM Treasury at any time.
Reporting requirement
Any activity conducted under General Licence INT/2022/2252300 must be reported to HM Treasury
within 7 days, with the details and supporting evidence requested in Part A or Part B. The reporting
forms referenced at 9.4 of Part A and 11.5 of Part B of General Licence INT/2022/2252300 may be
downloaded from the OFSI website at https://www.gov.uk/government/publications/reportingforms-for-ofsi-general-licence-int20222252300
Record-keeping requirements
A DP or Person must keep accurate, complete and readable records, on paper or electronically, of
any activity purporting to have been permitted under this licence for a minimum of 6 years.
Office of Financial Sanctions Implementation