OTSI Publishes Guidance on Licence Applications for Sanctioned Trade Services

On 10 October, OTSI published guidance on licence applications for sanctioned trade services. Under UK sanctions regimes, provision of certain trade services is prohibited, or subject to a licence or other exceptions.

It is important to consult sanctions laws to ensure that whatever service your company provides is legitimate. A services licence allows for the provision of services that would otherwise be prohibited under sanctions legislation.

Most prohibitions involve the Russia sanctions regime and include:

• Professional and business services:
  • accounting
  • advertising
  • architectural
  • auditing 
  • business and management consulting
  • engineering
  • IT consultancy and design
  • legal advisory
  • public relations
• Energy-related services, such as drilling, well testing, logging and completion services or the supply of specialised floating vessels  
• Infrastructure or tourism-related services to non-government-controlled Ukrainian territories  
• Interception or monitoring services

If your company is willing to provide these services to persons connected with Russia, you must apply for a trade licence.

There may be services prohibited under other sanctions regimes (e.g. Belarus, Myanma) which also require a licence.

There are, of course, situations when a licence is not required. 

Licences have an expiration date, and you will normally have reporting obligations under a licence.

Licence applications can be complex, and you may need some assistance with preparing one and complying with regulatory requirements. Gherson lawyers can advise you on the situations that require a licence, and can assist with licence applications and necessary reporting.

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.

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