Guidance: OFSI General Licence INT/2024/4761108

Why It Matters

It clarifies what personal banking activities are permissible under UK Russia sanctions, reducing compliance risk for individuals and businesses.

Key Takeaways

• Licence re‑issued 28 May 2024 under Regulation 64
• Allows personal‑use retail banking with designated institutions
• Payments must be strictly for the individual's personal needs
• Conditions include record‑keeping and reporting obligations
• Amendment extended licence validity in February 2026

Pulse Analysis

The United Kingdom’s Office of Financial Sanctions Implementation (OFSI) administers a complex web of sanctions designed to isolate Russia’s financial system after the 2019 EU Exit Regulations. General licences like INT/2024/4761108 are tools that provide limited, lawful pathways for specific activities that would otherwise be prohibited. By re‑issuing this licence, OFSI signals a calibrated approach: maintaining pressure on sanctioned entities while ensuring ordinary citizens retain access to essential banking services.

INT/2024/4761108 focuses exclusively on retail banking for personal use. Individuals can open accounts, receive salaries, and make everyday payments through designated banks, but they must demonstrate that every transaction serves a private, non‑commercial purpose. The licence imposes strict record‑keeping, requiring users to retain evidence of personal intent and to report any suspicious activity. Compliance teams therefore need to update internal policies, train staff on the personal‑use definition, and implement monitoring systems that flag commercial‑type transfers.

The broader market impact is twofold. First, financial institutions gain clearer guidance, reducing the operational burden of blanket refusals and the risk of inadvertent breaches. Second, the amendment in February 2026, which extended the licence’s validity, offers stability for cross‑border workers and expatriates who rely on UK banking for daily expenses. Companies with employees abroad should review payroll routing and ensure that salary payments fall within the licence’s scope, while legal advisers can use this precedent to anticipate future licence adjustments as the sanctions landscape evolves.