On 28 April, the Office of Financial Sanctions Implementation (OFSI) issued two new general licences and amended a licence on membership fees for international organisations.

Legal Fees Licence

New OFSI General Licence INT/2025/6160920 (“Legal Fees Licence”) permits a UK legal firm or UK counsel who has provided legal services to persons designated under UK Russia and Belarus sanctions regimes to receive payment from that designated person without applying for OFSI specific licence. The new Legal Fees Licence does not mirror the previous OFSI General Licences for Legal Fees INT/2022/2252300; INT/2023/2954852; INT/2023/3744968; INT/2024/4671884 or INT/2024/5334756, and it is imperative for anyone using it to consult the copy of the licence for definitions and permissions.

The new Legal Fees Licence resets the professional legal fees and expenses cap. Anyone relying on this licence can use the legal fees caps of £2,000,000 (including VAT if applicable) per Law Firm instructed in total for the duration of this licence, and the expenses caps (10% of the legal fees up to £200,000 (including VAT if applicable) under Parts A and B of the Legal Fees Licence.

The Legal Fees Licence defines Legal Services as services provided to a designated person, including legal advice and/or representation in court, whether provided within the UK or another jurisdiction, in relation to any matter except a claim for defamation or malicious falsehood.

For the first time, OFSI allows payment of expenses of up to £50,000 in relation to any designated person per Law Firm if it has not received professional legal fees and/or Counsel’s fees under the Legal Fees Licence.

The Legal Fees Licence took effect from 00:01 on 29 April 2025 and will expire at 23:59 on 28 October 2025. OFSI has the right to vary, revoke or suspend the licence at any time before its expiration date.

Integration of Credit Suisse Group AG and UBS Group AG

OFSI has issued General Licence INT/2025/6135848 , which allows the transfer of assets and liabilities of Credit Suisse Group AG to UBS Group AG. The licence is valid till 26 April 2030.

Membership fees for International Organisations

On 28 April, OFSI amended its Annex 1 of the General Licence INT/2025/5855272 to allow payment of subscription fees and any other payments required from the Government of Russia to retain membership in the International Maritime Organisation.

Under this Licence, 7 International Organisations based In the UK with recognised diplomatic status under international law are authorised to receive permitted payments from the Government of Russia from an account held with the Gazprombank Group.

Updated: 15 April 2025

If you have any questions arising from this blog, please do not hesitate to contact us for advice, send us an e-mail or, alternatively, follow us on X, Facebook, Instagram or LinkedIn to stay-up-to-date.

The information in this blog is for general information purposes only and does not purport to be comprehensive or to provide legal advice. Whilst every effort is made to ensure the information and law is current as of the date of publication it should be stressed that, due to the passage of time, this does not necessarily reflect the present legal position. Gherson accepts no responsibility for loss which may arise from accessing or reliance on information contained in this blog. For formal advice on the current law please do not hesitate to contact Gherson. Legal advice is only provided pursuant to a written agreement, identified as such, and signed by the client and by or on behalf of Gherson.

©Gherson 2025