Guidance: OFSI General Licence INT/2022/2300292

Why It Matters

The expanded licence streamlines compliance for UK utilities, ensuring essential services continue while adhering to evolving sanctions frameworks, and reduces administrative friction for payment processors.

Key Takeaways

• Allows cash utility payments under UK sanctions
• Extends coverage to gas and electricity meter work
• Removes frozen account restriction for designated persons
• Reporting deadline set to 30 days post‑quarter
• Includes 2025 migration and trafficking sanctions schedule

Pulse Analysis

The Office of Financial Sanctions Implementation (OFSI) uses general licences to carve out permissible activities within the UK’s strict sanctions regime. Licence INT/2022/2300292 was originally designed to enable utility providers to make payments that might otherwise be blocked under autonomous sanctions, safeguarding the continuity of essential services such as electricity and gas. By providing a clear legal pathway, the licence reduces the risk of inadvertent breaches and offers businesses a predictable compliance framework.

Recent amendments reflect the evolving needs of the utility sector and the broader sanctions landscape. The March 2026 update notably authorises cash transactions, a critical development for customers without digital banking access. Earlier changes in 2024 expanded the licence to cover meter installation, certification, and replacement, while the 2025 revision removed the frozen‑account limitation, allowing designated persons to receive payments from non‑frozen sources. Additionally, reporting obligations have been tightened, requiring quarterly submissions within 30 days, and the licence now references the 2025 Global Irregular Migration and Trafficking in Persons sanctions schedule.

For utility companies and payment processors, these refinements translate into operational efficiencies and reduced compliance costs. The ability to accept cash and handle a broader range of meter‑related activities without breaching sanctions encourages smoother customer interactions and supports infrastructure upgrades. Moreover, the clearer reporting timeline and expanded sanctions coverage help firms stay ahead of regulatory expectations, mitigating legal exposure and fostering confidence among investors and stakeholders in a highly regulated market.