 |
General Licence INT/2026/9512597 issued and 1 FAQ added, 1 FAQ withdrawn and 2 FAQs amended
On 24 April 2026, the General Licence INT/2026/9512597 was issued. The General Licence pertains to legal Services which will take effect following the expiry of Legal Services General Licence INT/2025/7323088 on 28 April 2026.
Any persons intending to use General Licence INT/2026/9512597 should consult the copy of the Licence for full details of the definition, permissions, and usage requirements.
FAQ 170 was withdrawn and FAQ 184 was added following the new General Licence. FAQ 50 and FAQ 57 were amended.
Don’t want to click? Here’s the new General License’s Publication Notice:
and the General Licence:
the new FAQ:
Legal Services General Licence (INT/2026/9512597)
184. The Legal Services General Licence has been updated and is available online. What has changed and what does this mean for law firms, legal advisors, Counsel and providers of Expenses?
General Licence INT/2026/9512597 refreshes the fees and expenses caps for Parts A and B for the six-month period from 29 April 2026 until 28 October 2026, when the licence expires.
In addition to refreshing the caps, OFSI has also made some amendments to the General Licence.
General Licence INT/2026/9512597 introduces a new definition:
‘DP Group’ means a DP designated for the purposes of an asset freeze by the UK under the UK Autonomous Sanctions Regulations, excluding those designated for the purpose of compliance with United Nations obligations, together with any entities owned or controlled by that DP.
Several permissions and conditions of the General Licence have been amended to incorporate this definition. Please consult the full licence online.
A DP and its owned or controlled entities may pay the legal fees for that DP or another entity within that DP group.
The Licence fee and expenses caps apply to all matters that a Law Firm (or Counsel, if engaged under a direct instruction) are handling for individuals or entities within a DP group, or, where there is no DP Group, for the designated entity or individual.
General Licence INT/2026/9512597 has also been amended to permit payments to a Non-UK Bank Account held by an individual regulated by the Solicitors Regulation Authority, the Law Society of Scotland or the Law Society of Northern Ireland, who provides Legal Services outside the United Kingdom, otherwise than at a branch of a Law Firm that falls within paragraph 8.2.1 (Part A) or 11.2.1 (Part B). Please consult the full licence for the complete permission.
Added on: 24 April 2026
and the amended ones:
Legal Services General Licence (INT/2024/5334756)
50. How do the fees and expenses caps apply? Is it per DP (i.e., for all a DP’s matters across all law firms) or is it per law firm being instructed by a DP?
OFSI has amended the General Licence so the £2,000,000 caps for each of Parts A and B, and the related expenses caps, now apply to each law firm instructed by the DP Group, or where there is no DP Group, to the designated entity or individual.
The caps cover all the matters being handled by that law firm for the DP Group, or where there is no DP Group, to the designated entity or individual. This means that the caps do not apply to each individual matter handled by that law firm.
Amended on: 24 April 2026
Scope of Legal Services General Licence
57. Can an entity owned and/or controlled by a designated person (DP) pay the DP’s legal fees even though the entity did not explicitly receive the legal advice?
Yes, provided the conditions of the General Licence are met. The General Licence states at paragraph 5 that a DP may pay professional legal fees, Counsel’s fees, and/or Expenses to a Law Firm, a Legal Adviser, Counsel or a provider of Expenses for Legal Services which have been provided to that DP or to any other DP in the same DP Group.”
The General Licence defines a DP as “those individuals or entities designated (or owned or controlled by an individual or entity designated) … excluding those designated for the purpose of compliance with United Nations obligations.”
Please see related FAQ 50.
Amended on: 24 April 2026
Leave a Reply