‘Not a policy shift’: OFSI updates National Settlement Depository FAQ

The UK’s Office of Financial Sanctions Implementation (‘OFSI’) has updated its General Licence INT/2025/6641960, 19 August, with the addition of Frequently Asked Questions 162-164.

On 18 July 2025, OFSI issued General Licence INT/2025/6641960 under the Russia and Belarus Regulations. The licence allows non-designated persons which have made investments through designated brokers to transfer their funds to a non-designated broker. The licence applies when the designated broker is the only designated party.

Regarding whether assets held by the National Settlement Depository are covered by the Brokerage General Licence, OFSI has answered ‘no’, stating that ‘the National Settlement Depository (“NSD”) is an entity designated by the [Foreign, Commonwealth and Development Office] FCDO for its role in supporting the government of Russia by providing key financial services. The Brokerage GL only applies to assets where the chain of custody involves one Designated Person, the broker itself. It does not give any permissions to the NSD to transfer funds that it holds some direct or indirect custody over.’

OFSI also clarified that the Brokerage GL does not represent a policy shift, and that the agency has no plans to issue a licence to release NSD-held funds. ‘OFSI has not changed its policy towards the NSD,’ the agency said, adding that it ‘assesses applications on a case-by-case basis’.

In answer to whether the Brokerage GL allows non-designated persons to terminate a banking relationship with designated brokers,OFSI reiterated its case-by-case stance, noting that ‘once the non-DP client funds are removed, the closure of the non-DP client’s account and termination of their contractual relationship with the DP Broker will not ordinarily engage sanctions. Therefore, OFSI does not consider a licence necessary to terminate the brokerage relationship once the funds are removed’.