October 26, 2026: OFSI updates Legal Services General Licence and Frequently Asked Questions


Office of Financial Sanctions Implementation HM Treasury

OFSI publishes updated General Licence for Legal Services and updates FAQs

On 26 October 2026, OFSI published an updated Legal Services General Licence INT/2026/11112108, which comes into effect 00:01 29 October 2026.

The updated General Licence refreshes the fees and expenses caps for Parts A and B for the six-month period from 29 October 2026 until 28 April 2027, when the licence expires.

In addition to refreshing the caps, OFSI has also made some amendments to the General Licence. These amendments are detailed in the accompanying publication notice and FAQ 206. FAQs 64, 71 and 75 have also been amended.

Any persons intending to use INT/2026/11112108 should consult the copy of the Licence for full details of the permissions and usage requirements.

Here’s the GL:

and the Publication Notice:

and all the relevant updated FAQs:

206. The Legal Services General Licence has been updated and is available online. What has changed and what does this mean for Law Firms, Legal Advisers, Counsel and providers of expenses?

General Licence INT/2026/11112108 refreshes the fees and expenses caps for Parts A and B for the six-month period from 29 October 2026 until 28 April 2027, when the licence expires.

In addition to refreshing the caps, OFSI has also made some amendments to the General Licence.

General Licence INT/2026/11112108 includes clarifications to the definition of Expenses and the permissions related to Expenses.

Amended definition: “Expenses” means any fees or expenses associated with the provision of the Legal Services including (but not limited to):

  • payments to other legal professionals instructed by the Law Firm and/or Counsel for third-party legal assistance.

The related amended permissions include paragraph 8.2.1, permission 5.1, Part A, and permission 4.1, Part B. OFSI has replaced the word “payable” with “paid” in these permissions:

“10% of the amount payable paid for professional legal fees and Counsel’s fees; or… “

See the full licence for the complete permissions.

General Licence INT/2026/11112108 updates paragraph 5, which now reads:

5. Subject to paragraph 6, provided that one (or both) of the sets of conditions in Part A and/or Part B of this licence are complied with in full, 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, or are being provided to that DP or to any other DP in the same DP Group.

General Licence INT/2026/11112108 updates permission 2, Part A:

2. The payment must be in relation to Legal Services which have been provided, or are being provided to a DP by a Law Firm, Legal Adviser or Counsel, or to Expenses.

General Licence INT/2026/11112108 removes the word “either” from permission 11, Part B:

11. Any payments made under this Part must either :

General Licence INT/2026/11112108 introduces a new reporting period. The reporting conditions now read:

Within 14 days of the end of each calendar month, any Person who has used the licence to receive payment for Legal Services provided to a DP must send to HM Treasury, by online reporting form

Please consult the full licence and other related FAQs for more information.

Added on: 26 October 2026

64. Which fees are not included in the £2,000,000 cap per part of the General Licence?

Expenses are not included in the £2,000,000 cap. Expenses include costs of travel, accommodation, translators, expert witnesses, and payments to other legal professionals instructed by the Law Firm and/or Counsel for third-party legal assistance. The General Licence can be used to pay expenses up to either 10% of the total professional legal fees and Counsel’s fees paid or £200,000, whichever is lower, under each part of the GL per law firm (or directly engaged Counsel) instructed.

Amended on: 26 Oct 2026

71. What counts as expenses under this General Licence?

All expenses associated with the provision of Legal Services to a DP excluding Counsel’s fees, such as the costs of travel, accommodation, translators, expert witnesses, payments to other legal professionals instructed by the Law Firm and/or Counsel for third-party legal assistance.

Amended on: 26 Oct 2026

75. What are my reporting obligations?

Any payments received for Legal Services provided to a DP under General Licence INT/2025/11112108 must be reported by online form to HM Treasury within 14 days of the end of each calendar month, with the details and supporting evidence requested in Part A or Part B of the General Licence.

Amended on: 26 Oct 2026


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