sanctions 29 February 2024

OFSI updates sanctions licensing process

The UK Office of Financial Sanctions Implementation (‘OFSI’) has updated its guidance ‘on how the Office of Financial Sanctions Implementation (OFSI) makes licensing decisions.’

In a blog post, it describes ‘both the process involved in obtaining a licence, from submitting an application to (if the licence is granted) receiving a final licence, as well as providing an update regarding the new Designated Individuals Licensing Principles which OFSI will apply in its decision making relating to designated individuals.’

It said those principles ‘will assist applicants to understand how OFSI interprets certain licensing purposes, common to all regimes, in relation to designated individuals. ‘For example, the principles help clarify OFSI’s view on what constitutes a basic need, or the kind of maintenance works that OFSI may license on a designated individual’s frozen assets. The principles will also help applicants to understand the circumstances under which OFSI may refuse to license certain activities, even where a licensing purpose is met.’

It says that applicants should ‘consider the principles carefully before making a licence application to OFSI,’ and that, ‘Although OFSI considers all licence applications on a case-by-case basis, applicants should expect a licence will not be issued if doing so would require OFSI to deviate from any of the principles.’

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