On March 28, 2025, the UK Office of Financial Sanctions Implementation issued the Arbitration Costs General License INT/2025/5787748 under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019 and regulation 32 of the Republic of Belarus (Sanctions) (EU Exit) Regulations 2019. General License INT/2025/5787748 was issued to enable persons to make payments to Arbitration Associations and Arbitrators to cover fees and expenses up to a maximum of £500,000 per arbitration. The license enables Arbitrators and Arbitration Associations to direct, receive and use these payments to cover Arbitration Costs. It also enables payments to be made to Designated Person (“DP”) Representatives and their Legal Representatives to cover Arbitration Costs and enables these Representatives to receive payments in order to pay for Arbitration Costs on behalf of a DP. The license also allows Relevant Institutions to process payments made in accordance with the terms of the license. Payments in excess of the £500,000 cap will require a specific license from OFSI.
Persons who receive payments under the Arbitration Costs General License are required to report the details and supporting evidence requested in the Arbitration Costs General License Reporting Form to HM Treasury within 30 days of receiving the payment. The license also requires DPs and persons that utilize the license to keep accurate and complete records of related transactions for a minimum of 6 years.
Because of the issuance of the new Arbitration Costs General License, OFSI revoked the London Court of International Arbitration (“LCIA”) General License INT/2022/1552576. As a result, payments that were previously permitted under the LCIA Costs General License will now be permitted under the Arbitration Costs General License.
On March 28, 2025, OFSI also revised General License INT/2023/2824812, which was issued under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations. The license, which permits transactions related to Bond amendments and restructurings for non-Designated Persons, was revised to extend the term of the license for an additional year, until March 27, 2026.
Arbitration Costs GL INT/2025/5787748 | Publication Notice – Arbitration Costs GL INT/2025/5787748 | LCIA Costs GL INT/2022/1552576 (Revoked) | Publication Notice – LCIA Costs GL INT/2022/1552576 | General License INT/2023/2824812 (Revised) | Publication Notice – General License INT/2023/2824812