OFSI Updates Guidance on Permitted Travel Expenses for Sanctions Licence Applications
OFSI has updated its guidance, ‘Permitted travel expenses for sanctions licence applications’, to clarify its expectations of applicants and align the guidance with wider OFSI guidance and current practice.
The update:
- Clarifies that the guidance applies not only to travel undertaken by designated persons, but also to travel undertaken by legal representatives or other individuals where an OFSI licence is required to make the relevant payments;
- Reflects current practice and expectations that applicants provide sufficient evidence at the outset and that OFSI may return an incomplete application for resubmission or refuse an application where adequate evidence is not provided;
- Confirms that in exceptional circumstances, OFSI may license a flight in a class above that which is normally permitted;
- Clarifies that where higher-cost travel or accommodation is not justified, OFSI may license a lower amount equivalent to permitted rates (subject to receiving sufficient evidence);
- Confirms that each application will be assessed on its own merits; and
- Removes outdated mileage rates and updates links to other relevant guidance.
And the guidance:
Guidance
Permitted travel expenses for sanctions licence applications
Updated 10 September 2026
This guidance is produced by the Office of Financial Sanctions Implementation (OFSI), part of HM Treasury, the authority for the implementation of financial sanctions in the UK.
This guidance sets out OFSI’s policy on licensing for travel and applies to travel and associated expenses for which an OFSI licence is sought. It is not limited to travel undertaken by the designated person or their dependents and may include travel undertaken by a designated person’s legal or other representatives where an OFSI licence is required to make the relevant payments.
This should be considered supplementary to, and not a replacement for, OFSI’s general guidance. Further sources of information that may prove helpful can be found at the end of this guidance.
This guidance does not represent legal advice.
If you are unsure about your obligations in a given case, you should consider seeking independent legal advice.
1. Licensing travel expenses
If you are applying for a licence from OFSI to release otherwise frozen funds for the purpose of travel and associated expenses, (for example, to allow you to attend legal meetings or court hearings), you will likely come across the term ‘reasonableness’. An associated expense may be incurred by attending legal meetings or court hearings for example, and when issuing a licence to enable the payment of such expenses, OFSI is legally obliged to ensure that those expenses are ‘reasonable’ as required under the various regime or sector specific regulations made under the Sanctions and Anti-Money Laundering Act (2018).
Each application is reviewed on a case-by-case basis and based on the facts provided, which may not necessarily be covered in this guidance.
Applicants may also apply for travel costs under another licensing purpose which does not carry a requirement for OFSI to conduct a reasonableness assessment. Nevertheless, they should provide a full explanation as to why a specific licensing ground applies to their case.
This guidance should be considered best practice and OFSI would expect the same considerations to be demonstrated. This guidance is not intended to cover all eventualities.
2. Applying for a licence
Various regime or sector specific regulations made under the Sanctions and Anti Money Laundering Act set out the basis upon which HM Treasury may issue a licence. The specific regime regulations appear on the financial sanctions targets by regime on GOV.UK.
It is important that applicants consult the relevant regulations before applying to OFSI.
Each set of regulations will have their own licensing purposes, but commonly the regulations will include two licensing purposes which include a ‘reasonableness’ test. These are ‘legal services’ and ‘maintenance of funds and economic resources’.
OFSI generally receives requests under these licensing purposes to enable the payment of:
• Reasonable professional fees for the provision of legal services
• Reasonable expenses associated with the provision of legal services
• Reasonable fees arising from the routine holding or maintenance of frozen funds or economic resources
• Reasonable service charges arising from the routine holding or maintenance of frozen funds or economic resources
It may be the case that other licensing grounds could be relevant to an application for travel expenses and applicants should provide an explanation as to why a specific licensing purpose reasonably applies to their case.
OFSI receives many licence applications where applicants have not provided sufficient evidence of reasonableness or with no evidence at all.
OFSI requires a significant level of evidence when scrutinising the reasonableness threshold. This is because the various specific regime regulations made under the Sanctions and Anti Money Laundering Act gives HM Treasury the power to issue licences, also stipulates legal fees and maintenance of funds and economic resources should be ‘reasonable’.
If OFSI does not receive the level of detail it needs, OFSI may deem the licence application incomplete and return it to the applicant for resubmission, or refuse the licence application.
In addition, applicants are strongly encouraged to apply to OFSI no less than four weeks in advance of making any travel arrangements.
Reasonableness may have different meanings in different contexts and applicants should note that just because a payment has been licensed in a previous case, does not necessarily mean that it will be licensed again. OFSI assesses each application on a case-by-case basis and applicants will be required to justify the proposed expenditure in each application.
OFSI does not want to cause delays to the consideration and issuance of any licence, so this guidance is aimed at setting out what information OFSI requires when considering if an application for travel costs is ‘reasonable’.
Before making any travel arrangements or applying to OFSI for a licence, you should consider the following four criteria:
Step 1. Consider alternatives to travel
As a first step in all cases, applicants should consider whether there are any practical alternatives to travelling in the first place, such as video, audio or web-based conferencing. They should explain why these alternative options are not possible in their particular case.
Step 2. Consider efficiency and cost-effectiveness
If travel is deemed to be the only option available, then consideration should be given to efficiency and cost-effectiveness (booking in advance, travelling off-peak, using timed trains, economy or standard class), safety and security.
Step 3. Consider necessity
OFSI would expect that only those individuals who absolutely must travel, do so. Support staff, such as paralegals, trainees and secretaries for example, should not be included unless deemed to be essential. In such cases, applicants should provide a clear explanation as to why these additional people are considered necessary and justifying the additional, proportionate cost.
Step 4. Apply for a licence before travel
Applicants should make an application for a licence to OFSI no less than 4 weeks in advance of travel and before making any concrete arrangements. Where an applicant is unable to apply for a licence 4 weeks in advance then explanation as to why should be provided.
3. Travel types
The rates shown in this section act as an indicator as to what OFSI would ordinarily deem to be reasonable. In exceptional cases, OFSI may issue a licence exceeding these rates. Applicants will need to provide a clear explanation of such additional costs being reasonable, including supporting evidence.
Designated persons subject to certain regimes may also be subject to a travel ban. The applicant should ensure that anyone subject to a travel ban also has permission to travel and the necessary supporting documents.
In the event of a licence being issued for a travel expense, any travel ban in place would still apply and is not negated by any licence that may be issued by OFSI. It is the applicant’s responsibility to ensure they are aware of any such restrictions.
3.1 Air travel
The cost of air travel is governed by the fare structure as set by airlines on various routes, as well as the duration of the flight and calendar dates. Prices often rise at popular times of the year, such as school breaks or national holidays, so OFSI would expect timings to be fully considered in line with the earlier pre-planning section.
For flights up to 6 hours, OFSI expects applicants to use economy class wherever possible, even if this means that flights may be very early or late, or alternative dates need to be considered.
For flights more than 6 hours, OFSI expects applicants to consider efficiency and cost effectiveness, safety and security when booking flights.
The table below should be used as a guide.
If there are exceptional circumstances where a flight in a class above what is permitted is needed, applicants should provide an explanation and supporting documentation.
Where exceptional circumstances have not been demonstrated and a flight in a class above what is permitted has been booked, OFSI will generally only license the cost equivalent of the fare of the permitted class of travel. In these circumstances, OFSI requires applicants to provide supporting evidence demonstrating the cost of the permitted fare. If this evidence is not provided, OFSI may refuse the entire amount.
Duration of flights[footnote 1] Class of flight which will normally be permitted Under 6 hours Economy and equivalent Over 6 hours Economy, Premium Economy and equivalents 3.2 Taxis
When making a licence application for taxi costs, the applicant will need to demonstrate that public transport has been considered and explain why the need for a taxi is appropriate and cost-effective.
Please note that carrying important documents will not generally in itself be considered an adequate justification. Many people can and do carry important documents, laptops etc on public transport.
3.3 Rail
When travelling by rail, OFSI expects applicants to travel standard class and generally at off-peak times. Moreover, OFSI expects that these rail tickets should be booked in advance, wherever possible, to take advantage of any discounts that may be available.
If an alternative class is required, applicants must explain how such costs are reasonable, like a higher class of air travel.
3.4 Hire Cars
The use of self-drive hire cars may be considered where this is cost-effective. The applicant will need to demonstrate their consideration of public transport options and explain how the need for car hire is appropriate and cost-effective.
3.5 Private vehicles and motor mileage allowance
The use of a private vehicle to travel on official business may be considered where the mileage rate provides a cost-effective means of transport. Applicants will need to provide mileage and destination details in their application and explain why this is cost-effective. Expected rates for mileage can be found at the link at the end of this document.
3.6 Hotels
OFSI will generally expect hotel stays to be minimised. Overnight accommodation should only be used where this is essential, for example, for a court hearing of more than one day. Applicants are expected to book the lowest reasonable class of hotel available, for example 3* rather than 5* wherever it is available. If overnight accommodation is essential, each case will be considered on its own merits. The general guidance provided by HMRC, which can be accessed through the link at the end of this document, will be a good indicator of costs that will be considered reasonable. Typically, OFSI would not licence a 4* and above hotel unless there are genuinely exceptional needs (such as a medical need for a particular facility). As with higher levels of air travel or rail travel, the applicant will need to explain how such costs are reasonable.
Where a 4* hotel or above is booked without demonstrating genuinely exceptional needs or the unavailability of suitable 3* accommodation, OFSI may instead license the cost equivalent of 3* accommodation. In these circumstances, OFSI requires applicants to provide supporting evidence demonstrating this cost. If this evidence is not provided, OFSI may alternatively license an amount capped at the costs outlined in the HMRC guidance.
3.7 Meals
Where meals are not included in the costs of the hotel or otherwise provided, it is possible to include these costs in the overall travel costs being applied for. The following table provides information on expected subsistence rates in the UK.
Meal Limit London Limit UK elsewhere Breakfast £6.00 £6.00 Lunch £10.00 £10.00 Dinner £25.00 £20.00 Subsistence rates outside of the UK will depend on the location of travel and will be assessed on a case-by-case basis.
4. Further support
For further support with UK financial sanctions, you can:
- Consult OFSI’s general, geographic and sectoral guidance
- Sign up to get UK sanctions email alerts
- Email OFSI on ofsi@hmtreasury.gov.uk
4.1 Further licensing information
OFSI’s Introduction to Licensing Blog
Leave a Reply