The Office of Financial Sanctions Implementation (OFSI) has published a blog outlining its updated approach to assessing reasonableness in licence applications across all UK financial sanctions regimes. The update introduces mandatory independent Costs Draftsperson’s Reports (CDPRs) for high-value legal fees applications, requiring a report where, within any six-month period, a UK law firm’s total legal and Counsel fees exceed £2m inclusive of VAT, or directly instructed Counsel’s fees exceed £1m inclusive of VAT. The thresholds apply per firm or per Counsel, per designated person, and cumulatively across related applications, with pro rata application for longer periods. CDPRs must be prepared by independent practising Costs Lawyers regulated by the Costs Lawyer Standards Board and not involved in the underlying matter. OFSI states that a CDPR will form part of the evidential package but will not be determinative, and it retains discretion to reduce or refuse the amounts sought. The costs of obtaining a CDPR may themselves be licensed, subject to the usual reasonableness test.

Law360, London: The head of the UK sanctions watchdog told MPs on 26 November 2024 to expect more fines with tougher penalties for breaches of financial restrictions to be imposed on oligarchs in the coming months as he admitted that the crackdown has been slower than hoped.

The Office of Financial Sanctions Implementation (OFSI) and the U.S. Office of Foreign Assets Control (OFAC) convened their annual technical exchange in October 2024, marking two years of enhanced partnership. Key developments include the signing of a Memorandum of Understanding (MOU) to bolster information sharing and collaboration, OFSI's introduction of FAQs to aid industry understanding of UK sanctions, and a joint review of the implementation of new Russian metals prohibitions. The exchange also focused on organisational modernisation, including the use of new technologies and the continuation of their reciprocal secondee programme. Both agencies reaffirmed their commitment to multilateral sanctions implementation, particularly in response to Russia's actions in Ukraine and ongoing conflicts in the Middle East.

The Office of Financial Sanctions Implementation (OFSI) has extended the General Licence INT/2022/1710676 - Evraz North American Subsidiaries. The General Licence now expires on at 23:59 on 31 March 2025.

The Office of Financial Sanctions Implementation (OFSI) and HM Treasury (HMT) have extended  General Licence INT/2022/2085212, regarding sanctioned Russian banks for Mongolian energy payments. The licence, effective from 7 August 2025, has been extended to expire at 23:59 on 14 August 2027.

The Office of Financial Sanctions Implementation (OFSI) has extended General Licence INT/2023/2824812, which relates to bond amendments and restructurings involving non-designated persons. The licence has been extended until 26 March 2028.

The Office of Financial Sanctions Implementation (OFSI) and HM Treasury (HMT) have extended General Licence INT/2023/3263556, initially issued under the Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855, allowing payments and activities related to insolvency proceedings for two Irish GTLK Companies and their subsidiaries. The licence, effective from 01 August 2023, has been extended to expire at 23:59 on 31 July 2030.

The Office of Financial Sanctions Implementation (OFSI) has extended General Licence INT/2025/7895596, which permits the continuation of business operations with Lukoil Bulgaria entities. The licence will now expire on 13 August 2026. The licence was originally issued on 14 November 2025 under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855, and was subsequently amended on 20 November 2025 to extend its scope to aviation and bunker subsidiaries. OFSI has also updated FAQ 173 of its UK Financial Sanctions FAQs to reflect the extension.

The Office of Financial Sanctions Implementation (OFSI) has extended General Licence INT/2025/8031092, which permits the continuation of business operations with Lukoil International entities. The licence will now expire on 25 August 2026. The licence was originally issued on 27 November 2025 under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855. OFSI has also updated FAQ 174 of its UK Financial Sanctions FAQs to reflect the extension.

The Office of Financial Sanctions Implementation (OFSI) has extended General Licence INT/2026/8893924, which permits the winding down of insurance policies written by Maritime Mutual entities and their subsidiaries before their designation. The licence will now expire on 8 July 2026. The licence was originally issued on 24 February 2026 under regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, SI 2019/855.

The Office of Financial Sanctions Implementation (OFSI) announced two licence updates. General Licence INT/2023/2824812 covering bond amendments and restructurings for non-designated persons has been extended until 27 March 2026. OFSI also amended General Licence INT/2024/5334756 to clarify that legal services include dispute resolution activities and that ownership/control criteria apply only to companies under the designated person definition.

The Office of Financial Sanctions Implementation (OFSI) and HM Treasury have updated General licence INT/2024/4919848 on sale, divestment and transfer of financial instruments held by the National Settlement Depository (NSD) and payment of safe keeping fees to the NSD. General licence INT/2024/4919848 now expires on 12 October 2024.