May 15, 2023

OFSI publishes guidance on license applications for travel

The UK Office of Financial Sanctions Implementation has published new guidance for persons applying for a license to release frozen funds for the purpose of travel and associated expenses.  Each license application is reviewed on a case-by-case basis.  The regulations for most UK sanctions regimes include two licensing purposes:  legal services, and maintenance of funds and economic resources.  A “reasonableness” standard is generally used to analyze the license applications for both purposes.

Through the guidance, OFSI encourages applicants to provide the level of detail needed to make a reasonableness assessment, in order to avoid delays.  Those seeking licenses are also asked to apply to OFSI at least four weeks in advance of the proposed travel.   A license allowing travel expenses does not affect the operation of any existing travel ban, which would remain in force.

In making its reasonableness assessment, OFSI considers multiple factors, including:

  • Whether alternatives to travel exist (video or audio conferencing, for example);
  • Best option for limiting excessive dissipation of the frozen assets (traveling off-peak, booking economy class tickets, using standard rather than luxury accommodations);
  • Necessity, meaning that only essential personnel should be allowed to travel – this may exclude trainees, paralegals and other support staff, unless the cost of their inclusion can be justified;
  • Whether there exist exceptional circumstances demonstrating the need for a higher level of expenses.


Whilst recognizing that each case is different, the guidance lists the expected class and transportation mode for specific trip durations, sets forth the basis for calculating costs in private vehicles, and offers a table of meal cost allowance within London and elsewhere in the United Kingdom.

OFSI reminds applicants that sanctions breaches – including breaches of the terms of a license — are serious criminal offenses punishable by up to seven years in prison, and that its powers under the Policing and Crime Act (2017) allow the agency to impose monetary penalties of 50% of the total value of the sanctions breach or £1 million.