Alex Mullen, during a secondment to the sanctions team at BCL Solicitors LLP, works with John Binns to analyse the Office for Financial Sanctions Implementation's new General Licence, and whether it delivers what it promises.
Designated Persons (‘DP’) and their lawyers would be forgiven for getting excited on 22 May 2023 with the release of the Office for Financial Sanctions Implementation’s (‘OFSI’) new ‘Prior Obligations’ Licence (INT/2023/3024200) which, on its face, promises a great deal. The devil, however, is in the detail.
The Licence comes amidst what OFSI describe as “…unprecedented numbers of licence applications to permit prohibited transactions or activities owing to more sweeping and far-reaching sanctions imposed relating to Russia and Belarus.”
“It is extremely important to OFSI that UK persons are not unintentionally disadvantaged by the financial sanctions imposed on Russian and Belarusian DPs”, OFSI say.
Read the full article HERE.
Alex Mullen