On October 19, 2023, the UK Office of Financial Sanctions Implementation amended General License INT/2023/3626884 which was issued under all UK Autonomous Sanctions to enable UK designated persons (“DPs”) to make permitted payments to Companies House. Initially, permitted payments included fees owed by UK DPs to Companies House for the filing of confirmation statements for UK companies and late filing fees incurred in connection with the late filing of a confirmation statement. However, the amendment refines the definition of permitted payments and now enables UK DPs to pay fees to Companies House for the filing of confirmation statements concerning “entities incorporated in the UK.” The amendment also allows DPs to pay late filing penalties owed to Companies House as the result of the late filing of “annual accounts by those UK DPs.” The amended license also updates the definition of a UK DP. While the term originally meant any entity designated by the UK for the purposes of an asset freeze under the UK Autonomous Sanctions Regulations, UK DP now includes entities that are owned or controlled by a designated “individual” or entity.
All other license provisions remain the same. The general license does not permit payments to any person designated by the United Nations. In addition, UK DPs who utilize this general license are still required to report the following details and supporting evidence to OFSI within 14 days of making a Permitted Payment: i) the type of Permitted Payment made; ii) the amounts paid; iii) the payment route used; and iv) the date of payment. UK DPs must also keep accurate and complete records of actions taken pursuant to this license for a minimum of 6 years.