OFSI Issues Second Legal Fees General Licence

The Office for Financial Sanctions Implementation ("OFSI") has issued a second general licence with respect to the Russia and Belarus sanctions regimes for the payment of legal fees (INT/2023/2954852, "the New Licence"), following the expiry of the one issued on 28 October 2022 (INT/2022/2252300, "the Old Licence").

Whilst the Old Licence was a welcome step when issued, significant uncertainty arose from various ambiguities in its drafting.

The New Licence addresses some of these ambiguities but leaves others outstanding. It also implements UK government policy on Strategic Litigation Against Public Participation ("SLAPPs") by excluding legal services that relate to claims for defamation or malicious falsehood.