March 5, 2018: HMT updates its financial sanctions general guidance

OFSI updates legal services guidance



As part of its ongoing review of licensing policy, OFSI has updated its operational policy on licensing legal services.

OFSI’s updated guidance now states that obtaining a licence is encouraged, rather than mandated, in advance of providing substantive legal services. No payment for legal services by, or on behalf of, a designated person should be received in the absence of a licence from OFSI.

This revised approach is aligned to EU legislation which contains a licensing ground enabling OFSI to permit payment of reasonable legal fees and expenses – from frozen funds or third party funds – on behalf of a designated person.

Frequently Asked Questions 3.4.1 and 3.4.2 in the general guidance have been updated to reflect this change.


Financial sanctions: general guidance

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