OFSI Applications

Key takeaways

OFSI, part of HM Treasury, implements UK financial sanctions and decides licence applications, while most designations are made by the FCDO.
An OFSI licence permits an act that financial sanctions would otherwise prohibit; it cannot be backdated, and OFSI does not charge a fee for it.
General licences can be used without applying, but each sets its own conditions, such as record-keeping and reporting.
If no general licence fits, you need a specific licence based on a licensing ground in the regulations, applied for through OFSI’s online form.
Breaching financial sanctions can lead to up to 7 years’ imprisonment or a civil penalty of up to £1,000,000 or 50% of the breach value, whichever is greater.

An OFSI licence is written permission from the Office of Financial Sanctions Implementation to carry out an act that UK financial sanctions would otherwise prohibit, such as paying a designated person’s rent, receiving payment for legal work or releasing funds owed under a contract signed before designation. Without a licence, the same payment can be a criminal offence or lead to a civil penalty.

Sterling Law advises individuals, businesses and professional firms on whether a licence is needed, which general licence may apply and how to prepare a complete specific licence application.

What is OFSI?

OFSI is the Office of Financial Sanctions Implementation, part of HM Treasury. Set up in March 2016, it implements and enforces the UK’s financial sanctions: it publishes guidance, grants licences, investigates suspected breaches and imposes civil penalties.

Under most UK regimes, designations are made by the Foreign, Commonwealth and Development Office (FCDO), not by OFSI, and published in the UK Sanctions List, the only official list of UK designations since 28 January 2026. Certain trade sanctions are enforced separately by the Office of Trade Sanctions Implementation (OTSI). Our sanctions law team can check which regime applies to you.

Types of OFSI Licences

OFSI issues two types of licence: general licences, which anyone can rely on if they meet the conditions, and specific licences, which are granted to a named applicant for a particular activity.

General Licences

An OFSI general licence allows a stated activity that would otherwise breach financial sanctions, and anyone who falls within its terms can use it without applying. OFSI does not accept applications for general licences: it issues them where the same activity affects many people, for example household payments by designated persons or humanitarian work.

Each general licence sets its own conditions. Most require you to keep records, many require you to report to OFSI, and some require you to notify OFSI when you start using them. General licences can be amended, suspended or revoked at any time, so check the current version on the OFSI general licences page on GOV.UK. If a general licence covers your activity, OFSI expects you to use it rather than apply for a specific licence.

Which OFSI General Licences Are Currently in Force?

As of 2026, OFSI lists around 60 general licences in force. Those most often relevant to individuals and businesses dealing with a designated person are:

General licence	Reference	What it covers
Legal Services	INT/2026/11112108	Legal fees for persons designated under most UK autonomous regimes, within caps; in force until 28 April 2027
Interim Basic Necessities for Designated Persons	INT/2025/5632740	Up to £350 a month for an individual’s food, medicine and household goods in the first two months after designation
Payments to Utility Companies for Gas and Electricity	INT/2022/2300292	Gas and electricity for UK properties that a designated person owns or rents
Payment to Water Companies for Water and Sewage	INT/2023/3179120	Water and sewerage for UK properties that a designated person owns or rents
Service Charge and Ground Rent Payments	INT/2026/10050568	Service charges and ground rent under leases in England or Wales made before designation
Permitted Payments to UK Insurance Companies	INT/2022/2009156	Buildings, property-related liability and motor insurance premiums
Payments for Visa Application Services	INT/2024/4907888	Fees of the Home Office’s contracted visa application service providers

Each licence has its own regimes, conditions and limits, and most do not apply to persons designated under UN sanctions.

Specific Licences

A specific licence is written permission granted to a named person for a particular activity, such as a payment from a frozen account. Under regimes made under the Sanctions and Anti-Money Laundering Act 2018, OFSI can grant one only where the activity falls within a licensing ground in the regulations and every condition of that ground is met. The most common grounds cover:

basic needs of a designated individual and their dependants, or costs strictly necessary for a designated company’s continued existence;
reasonable legal fees and related expenses;
the routine holding and maintenance of frozen funds;
extraordinary expenses where no other ground fits;
judicial, administrative or arbitral decisions;
prior obligations that arose before designation;
humanitarian assistance and diplomatic missions;
extraordinary situations, insolvency and, under the Russia regime, divestment.

The grounds differ between regimes, and some are not available for persons designated under UN sanctions.

Licences for Legal Fees

A law firm can usually act for a designated person without a licence, but it cannot receive payment for that work, from frozen funds or from someone paying on the client’s behalf, unless a licence permits it: the Legal Services General Licence, where it applies, or a specific licence. For a specific licence the fees must be shown to be reasonable, and for large matters OFSI requires a report from an independent costs lawyer. We explain the thresholds in our article on OFSI legal fee licences and independent costs assessment.

Why is an OFSI Licence Necessary?

An OFSI licence is necessary because dealing with a designated person’s frozen funds, or making funds available to them, is prohibited unless an exception or a licence applies. Acting without a licence, or outside its terms, can lead to serious penalties.

Consequence	Possible penalty
Criminal prosecution	Up to 7 years’ imprisonment, a fine or both
Civil monetary penalty imposed by OFSI	Up to £1,000,000 or 50% of the estimated value of the breach, whichever is greater

For breaches on or after 15 June 2022, OFSI does not have to prove that the person knew or suspected they were breaching sanctions. In practice, banks also usually will not process a payment involving a designated person without a licence that covers it, although a licence does not oblige a bank to pay. If your account has been frozen, see our guidance on dealing with frozen bank accounts.

How to Apply for an OFSI Licence

To apply for a specific licence, you complete the online OFSI licence application form on GOV.UK, introduced on 17 July 2025. Applications under the counter-terrorism regimes are made by email.

Check that a designated person, or a company they own or control, is involved, that the activity has a connection to the UK and that no exception or general licence already covers it.
Identify the sanctions regime and licensing ground, and explain how each condition is met.
Set out the transaction: amounts, dates, purpose, every party including banks and intermediaries, and the full payment route.
Attach supporting documents, such as contracts, invoices and leases, and explain why the amount is reasonable; up to four files of 7MB can go with the form, and more once OFSI gives you a case reference.
Answer OFSI’s questions promptly and check the draft licence if OFSI sends one.

Incomplete applications are returned without being considered. Where the origin of the money is in question, a source of wealth and source of funds report can support the application.

How Long Does an OFSI Licence Application Take?

OFSI does not publish a fixed processing time. It ranks applications as high, medium or low priority against seven criteria. Basic needs, humanitarian and risk-to-life cases are generally treated as high priority, but even these can take time, and complex applications can take several months.

Because licences cannot be issued retrospectively, apply as early as possible and ask for any amendment or extension well before a licence expires.

Licence Conditions, Reporting and Changes

Every licence has conditions: a payment made by another route, above the permitted amount or after expiry is a breach of sanctions. Many licences require reports to OFSI, and most require records to be kept. To change a specific licence, you request an amendment, variation or extension through the same online form.

Separately, relevant firms such as banks, law firms, accountants and estate agents must tell OFSI as soon as practicable if they know or have reasonable cause to suspect that a person is designated or has breached sanctions. Anyone holding a designated person’s funds or economic resources must also report them to OFSI by 30 November each year.

How Can Sterling Law Assist?

Sterling Law advises individuals, businesses and professional firms whose payments, accounts or contracts are affected by UK financial sanctions.

Our work can include:

checking whether a payment needs a licence;
identifying an exception or general licence that already applies;
preparing specific licence applications, including legal fee licences;
answering OFSI’s questions and reviewing draft licences;
applying to amend, vary or extend a licence;
setting up licence reporting and record-keeping;
advising on reporting duties and voluntary disclosure of a possible breach;
advising on frozen crypto accounts and bank accounts closed because of sanctions.

Our sanctions work includes an OFSI licence that allowed a company’s frozen funds to be released to its UK bank account, and a submission to OFSI, which then found no breach of financial sanctions in a transaction involving a Russian bank.

FAQ

Who can apply for an OFSI licence?

Anyone who needs a licence for a particular act: the designated person, or a bank, law firm, landlord or business that needs to deal with frozen funds or make funds available to a designated person.

Can I apply to OFSI for a general licence?

No. OFSI does not accept applications for general licences: you check whether a published one covers your activity and follow its conditions.

How do I apply for an OFSI licence?

Through OFSI’s online application form on GOV.UK, giving the sanctions regime, the licensing ground, full details of the payment and supporting documents.

How long does an OFSI licence take?

OFSI publishes no fixed timescale. Urgent cases such as basic needs and humanitarian activity are generally treated as high priority, while complex applications can take several months.

Will OFSI always grant a licence?

No. OFSI can grant a licence only where a licensing ground applies and its conditions are met; if it refuses, it gives reasons, and you can reapply with further evidence.

Who needs to report to OFSI?

Relevant firms, such as banks, law firms and estate agents, must report known or suspected designated persons and breaches, and anyone holding a designated person’s funds must report them by 30 November each year.

What happens if you breach financial sanctions?

You can face up to 7 years’ imprisonment, or a civil penalty from OFSI of up to £1,000,000 or 50% of the value of the breach, whichever is greater.

What is the difference between OFSI and OTSI?

OFSI, part of HM Treasury, enforces financial sanctions and grants financial sanctions licences, while OTSI enforces certain trade sanctions.

Sources

Last reviewed: November 2026.