On April 26, 2022, the UK’s Office of Financial Sanctions Implementation issued a new general license under Regulation 21 of the Global Anti-Corruption Sanctions Regulations 2021 and Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 to address officers of Non-Crown Relevant Organizations and their duty to engage in certain actions for Asset Recovery Purposes in accordance with UK legislation or common law. Subject to the conditions set out in the license, General License INT/2022/1679676 permits these officers to engage in any action necessary to comply with the following:
i. UK court orders obtained by Relevant Organizations for Asset Recovery Purposes,
ii. Forfeiture notices provided by officers of Relevant Organizations, or
iii. Other types of external orders that are referred to in paragraphs 4.2 (c) – (e) of General License INT/2022/1679676.
Under the general license, permissible Asset Recovery Purposes include negotiated settlements involving parties that are Relevant Organizations or approved deferred prosecution agreements involving parties that are Crown Relevant Organizations. This general license is effective on April 27, 2022 for an indefinite duration, unless varied, revoked or suspended by HM Treasury.
Any person interested in conducting an activity under this general license on behalf of any organization that is “not explicitly named in the license” must request permission from OFSI in writing prior to engaging in the activity. In addition, anyone utilizing this general license is required to keep accurate records of these transactions for a minimum of 6 years, and any transactions involving a designated person’s assets must be reported to HM Treasury within 28 days.