OFSI amends General Licence on insolvency-related payments and activities involving GTLK companies and their subsidiaries

On 12 June 2025, the Office of Financial Sanctions Implementation (“OFSI”) amended its General Licence INT/2023/3263556: GTLK Companies and their Subsidiaries – Insolvency-related payments and activities (“General Licence”).

GTLK JSC is Russia’s largest leasing transport company which was designated by the UK Government in April 2022. Its associated entities include GTLK Europe and GTLK Capital; both companies are incorporated in Ireland.

 The new changes under the General Licence include:

• Inclusion of Regulation 18A of The Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”) to the regulations that are exempt under this General Licence.
• Inclusion of definitions for ‘Notes’, ‘Noteholders’, ‘Trustee’, ‘Relevant non-UK Institution’, ‘UK Prohibited Persons’ and ‘UK Prohibited Person’s Account’.
• Addition of Permission 4.3 to the General Licence, which states that no financial services for foreign exchange reserve and asset management shall be provided to a UK Prohibited Person unless any resulting payments are ultimately credited to a UK Prohibited Person’s Account. The definition of a UK prohibited person for the purposes of the General Licence is taken from Regulation 18A (2) of the Russia Regulations.
• Addition of new reporting obligations which need to be fulfilled within 14 days of making any distributions in respect of the Notes under the General Licence.
• Clarification in Permission 4.2 of the General Licence that any funds made available to designated persons must be held in a frozen account and any economic resources made available must be treated as frozen.
• Amendments to the existing notification requirement and the record-keeping requirement.

If you think that this General Licence is applicable to your business and require further assistance with its implementation, please contact our lawyers for more information.

Updated: 13 June 2025

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