On 28 July 2022, the Office of Financial Sanctions Implementation (OFSI) updated its general guidance for financial sanctions under the Sanctions and Anti-Money Laundering Act 2018. The guidance outlines firms’ obligations under financial sanctions, as well as OFSI’s approach to licensing and compliance issues. It takes into account relevant case law and guidance at the date of publication.

Amendments to the guidance include changes to OFSI’s licencing timeframes. The previous guidance stated that OFSI aimed to engage with applicants on the substance of completed applications for specific licences within four weeks. Section 6.10 now outlines that OFSI will aim to review all new licensing applications “as soon as practicable”. It will prioritise cases at times of high demand, and in particular where there are issues of personal basic needs and/ or wider humanitarian issues at stake which are of material impact or urgency, or which are deemed to be of particular strategic, economic or administrative importance.

License applications should be submitted to OFSI well in advance of the date from which the license is required, with comprehensive supporting information. Where applicable general licenses are in place, firms should ensure that any relevant transactions take place before the general license expires rather than submitting an application for a specific license after this date. Specific applications submitted after such an expiry date are unlikely to be prioritised.