News
Update your policies to reflect new sanctions licence
11 November 2025
The Office of Financial Sanctions Implementation (OFSI) has issued a new General Licence, which took effect on 28 October 2025.
The new General Licence permits UK legal firms, legal advisers, counsel and providers of expenses (as defined in the licence) to receive payment for legal services provided to designated persons under the UK's autonomous sanctions regimes, without needing to obtain an individual OFSI licence.
The scope, definitions and conditions of the new licence differ from earlier versions, so firms should carefully review its terms to ensure full compliance before it takes effect.
The licence replaces several earlier legal-services licences. Firms should update internal policies, client onboarding procedures and billing processes to align with the new requirements.
In addition, OFSI's publication notice highlights two key points:
- The new General Licence INT/2025/7323088 now covers most UK Autonomous Sanctions Regimes. See Annex 1 of the General Licence for a table listing the regimes covered.
- The General Licence does not permit payment directly or indirectly to or for the benefit of any person designated for the purpose of compliance with United Nations obligations.
OFSI is expected to issue further guidance in due course to help firms understand the new licence's scope and confirm how payments should be managed.
Separately, the UK Sanctions List has become the only official sanctions list detailing all sanctions designations published by the UK Government.
This change will simplify the UK sanctions framework and make it easier for firms, regulators and the public to identify designated individuals and entities. All existing designations will be transferred to the new consolidated list, which will replace the current format separating financial and trade sanctions entries.
Firms should ensure their sanctions screening systems, compliance frameworks and internal documentation are updated to prevent any disruption in screening accuracy.
Any internal materials or checklists referring to the previous lists should be reviewed and amended to reflect the single-list approach ahead of implementation.
We encourage firms to monitor OFSI updates and prepare for both changes to maintain robust compliance with the UK's sanctions regime.