OFSI General Licence – INT/2022/1947936 amended and 2 FAQs amended

On 5 February 2026,  the General Licence INT/2022/1947936 was amended. Annex I was amended to remove Bank FC Otkritie and replace it with BM-Bank, reflecting their merger.

Any persons intending to use General Licence INT/2022/1947936 should consult the copy of the Licence for full details of the permissions and usage requirements.

On 5 February 2026, FAQs 147-148 were amended to reflect the amendment of OFSI General Licence – INT/2022/1947936.

From the FAQ page:

147. My OFSI licence(s) still mention(s) Bank Otkritie following its merger. What should I do?

Bank Otkritie, which was Designated under the Russia (Sanctions) (EU Exit) Regulations 2019, ceased to exist as a separate entity when it merged with BM-Bank as of 1 January 2025. BM-Bank remains designated as a result of its ownership and control by the designated entity VTB Bank. OFSI has amended the Humanitarian Activity General Licence INT/2022/1947936 to reflect the merger with BM-Bank and you may continue to rely on this General Licence, provided you otherwise comply with its terms and conditions. Should you hold a live specific licence referencing Bank Otkritie, and you wish to continue relying on this licence, then you should immediately request an amendment to your licence from OFSI as OFSI would consider it a breach of sanctions if entities/individuals continued using their licence without the correct licence permission in place.

Amended on: 05 Feb 2026

148. Will OFSI amend General Licences affected by the mergers of Rosbank PJSC and Bank Otkritie with BM-Bank?

OFSI has amended the affected live General Licences, including those impacted by the merger of Rosbank PJSC and the merger of Bank Otkritie with BM-Bank. Therefore, entities/individuals relying on these General Licences can continue to do so. OFSI will not proactively identify specific licences referring to these entities.

Amended on: 05 Feb 2026