October 31, 2022

OFSI issues Russia- and Belarus-related general license to authorize the payment of legal fees under certain conditions

On October 28, 2022, the UK Office of Financial Sanctions Implementation issued General License INT/2022/2252300 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 (the “Russia Regulations”) and under Regulation 32 of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 (the “Belarus Regulations”). This general license temporarily authorizes, under certain conditions, the payment of professional legal fees, counsel’s fees, and expenses relating to the provision of legal services.  In particular, under the general license, a body of persons (a “Person”) may receive payments from any individual or body of persons designated under regulation 5 of the Russia Regulations or the Belarus Regulations and/or any individual or body of persons owned or controlled by that designated person as determined under the criteria set out in the same regulations (“DP”); make payments for, on behalf of, or for the benefit of, a DP; process payments related to a DP; and perform any other acts that are reasonably necessary to give effect the aforementioned payments, provided that the conditions set out in Part A (legal services based on a prior obligation) or Part B (legal services not based on a prior obligation) are complied with in full.  This license expires on April 28, 2023. 

Any DP or Person that conducts activity under GL INT/2022/2252300 must report the transaction to HM Treasury within 7 days along with any details and supporting evidence requested under Part A or Part B of the license as applicable. In addition, any DP or Person who utilizes this general license must keep complete and accurate records related to the permitted activity for a minimum of 6 years.

General License INT/2022/2252300 | General License INT/2022/2252300 – Publication Notice