Guidance: OFSI General Licence - INT/2026/9512597

Why It Matters

By removing the need for case‑by‑case licences, the new OFSI General Licence reduces administrative overhead and accelerates payment flows for UK legal firms serving sanctioned clients, enhancing operational efficiency and regulatory certainty.

Key Takeaways

• New OFSI General Licence INT/2026/9512597 replaces 2025/7323088.
• Applies to UK legal firms advising persons under listed sanctions.
• Permits direct payment from designated persons without separate licence.
• Covers all regimes in Annex 1 of the General Licence.

Pulse Analysis

The Office of Financial Sanctions Implementation (OFSI) administers the United Kingdom’s autonomous sanctions, a toolkit used to curb illicit activity and foreign policy threats. General licences are a core feature of this regime, offering pre‑approved permissions that bypass the need for individual applications. Historically, legal advisers working for sanctioned individuals required a specific OFSI licence to receive fees, creating a bottleneck for cross‑border counsel and adding compliance costs. The new General Licence INT/2026/9512597 reflects OFSI’s effort to simplify these procedures while maintaining strict oversight.

INT/2026/9512597, effective after the expiry of the 2025 licence on 28 April 2026, expands the scope of permissible activities for UK‑based law firms. It authorises firms that have provided legal advice to persons designated under any of the UK’s autonomous sanctions regimes listed in Annex 1 to accept payment directly from those persons. This eliminates the need for a separate, case‑by‑case licence, reducing administrative lag and legal uncertainty. The licence’s nine‑page guidance outlines eligibility criteria, reporting obligations, and compliance checks, ensuring firms can operate within a clear regulatory framework.

For the legal sector, the licence signals a more predictable environment for handling high‑risk clients. Firms can now streamline invoicing and cash‑flow processes, freeing resources for substantive legal work rather than licensing paperwork. The broader market may see increased competition as smaller firms gain the same access to sanctioned clientele without prohibitive licensing costs. However, firms must still conduct robust due‑diligence to avoid inadvertent breaches, as the licence does not waive underlying sanctions obligations. Overall, the change underscores the UK’s intent to balance sanction enforcement with pragmatic business facilitation.