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Humanitarian General Licence for OSFI’s Russia sanctions

OFSI General Licence – Russia

OFSI has issued General Licence INT/2022/1947936 under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019

Under General Licence INT/2022/1947936 relevant persons seeking to undertake humanitarian activity in relation to the conflict in Ukraine do not need to apply for individual licences from OFSI, but instead can rely on the permissions within this General Licence.

OFSI has also published a blog outlining the details of the General Licence

This licence takes effect from 11:59 pm on 7 July 2022.

Any Persons intending to use the General Licence should consult the copy of the Licence and refer to OFSI’s General Guidance.

And here’s that blog post:

OFSI issues Humanitarian Activity General Licence under Russia sanctions regime

Posted by: OFSI, Posted on: 7 July 2022 – Categories: CharitiesComplianceenforcementFinancial sanctionsLicensing

UK has introduced the largest and most severe package of economic sanctions that Russia has ever faced. The whole of the UK government, along with our international allies, is working to damage Putin’s ability to wage war.

The UK’s total offer of grant aid to Ukraine now totals almost £400m, including £220m of humanitarian aid – making the UK a leading bilateral humanitarian donor to Ukraine. Creating space for impartial humanitarian action remains a priority in our response. OFSI, along with departments across government, has worked to minimise any unintended consequences of sanctions on the delivery of such humanitarian support to affected populations, for example through using humanitarian licensing provisions.

However, as the number of designations has increased, the Government recognises the increasing possibility that parts of the humanitarian supply chain may be captured by these designations. This means there could be an increasing number of license applications needed to ensure that humanitarian assistance does not breach sanctions regulations.

Therefore, OFSI has sought to further assist the efforts of humanitarian actors by issuing a General Licence to allow the timely delivery of humanitarian assistance activity in relation to the conflict in Ukraine. This means that relevant persons seeking to undertake such activity do not need to apply for individual licences from OFSI, but instead can rely on the permissions within this General Licence.

In recognising the wide-ranging need for humanitarian assistance as a result of the conflict, the General Licence covers activity in relation to the conflict in Ukraine, including the non-Government controlled regions of the country – this includes Crimea and other non-government-controlled areas of Ukraine, such as the Donetsk and Luhansk Oblasts.

The General Licence also contains permissions for relevant UK financial institutions to carry out any activity to effect the delivery of humanitarian assistance, and other activities that support basic needs in relation to the conflict in Ukraine, as they play an important role in working with NGOs to deliver humanitarian assistance.

There are however important conditions set out in the licence. These include for example, permissions only extending to an approved category of organisations (relevant persons), and also ensuring that any funds used for humanitarian assistance and meeting basic needs, must not be funds or economic resources that are owned, held or controlled by a Designated Person (DP). This is to ensure that DPs cannot release frozen assets without prior permission from OFSI and prevent the terms of the licence being misused by DPs. However, the General Licence will still permit relevant persons to interact with designated financial institutions where they are necessary to delivering humanitarian aid. Anyone seeking to rely on the permissions outlined in the General Licence should consult a copy of it before undertaking any activity.

The Government, including OFSI, will work with stakeholders including humanitarian organisations and their financial service providers, to continue to monitor the effectiveness of this general licence in order to ensure that the sanctions against Russia remain effective while not impeding delivery of humanitarian assistance.

Links:

General Licence INT/2022/1947936 – General Licence

Blog post

Categories: Humanitarian Aid Licenses OFSI Updates Russia sanctions

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