Mr. Sanctions

Category: OFSI (UK)

  • August 6, 2026: OFSI adds 1 person, 12 entities and 6 cargo vessels to Russia sanctions

    UK Gov logo, 50% resolution.png

    Today, Thursday 6th August, the UK Government has designated the following individual and 12 entities, and specified the following 6 ships, under the Russia (Sanctions) (EU Exit) Regulations.

    Designated Individual:

    Name:Unique ID:
    Aleksander Aleksandrovich ZHDANOVRUS3708

    Designated Entities:

    Name:Unique ID:
    NORTHERN ENGINEERING LIMITED LIABILITY COMPANYRUS3701
    FRION SHIP MANAGEMENT LLPRUS3703
    LLC METALLKOMPLEKTRUS3704
    LLC NIKOMRUS3705
    LLC PROMSIZRUS3706
    LLC TECHNOLUXRUS3707
    LIMITED LIABILITY COMPANY “OZON BANK”RUS3709
    STATE SPECIALIZED RUSSIAN EXPORT-IMPORT BANK (JOINT-STOCK COMPANY)RUS3710
    PJSC COMMERCIAL BANK “CENTER-INVEST”RUS3711
    JOINT STOCK COMPANY REALIST BANKRUS3712
    PJSC BANK STAVRRUS3713
    JOINT STOCK COMPANY TELEPORT BANKRUS3714

    Specified Ships:

    Name:Unique ID:
    IMO 9333591 (“ARCTIC EXPRESS”)RUS3702
    IMO 9326811 (“PERSEAS”)RUS3715
    IMO 9470131 (“TORVIAN”)RUS3716
    IMO 9402263 (“ASTERAS”)RUS3717
    IMO 9378864 (“VISUND”)RUS3718
    IMO 9346885 (“ZENTURO”)RUS3719

    And the Sanctions Notice:

    Sanctions_Notice__Russia__06_August_2026Download

    and even a press release from FCDO:

    UK continues crackdown on Russia with tough new sanctions

    The UK government continues to demonstrate unwavering support for Ukraine as Foreign Secretary Ed Miliband unleashes his first major Russia sanctions package.From:Foreign, Commonwealth & Development Office and The Rt Hon Ed Miliband MPPublished:6 August 2026

    • Foreign Secretary Ed Miliband steps up UK action against Russia, with new sanctions targeting the Kremlin’s military machine, oil and gas revenues and ageing shadow fleet.  
    • Government continues to support Ukraine after the Prime Minister and Foreign Secretary welcomed President Zelenskyy to the UK last week. 

    Russian banks, shadow fleet ships and shady businesses have been slapped with UK sanctions for their role in Russia’s barbaric war on Ukraine. 

    In his first major sanctions package, Foreign Secretary Ed Miliband has reinforced the UK’s commitment to the people of Ukraine by announcing new measures against those supporting the Kremlin’s war effort. 

    The package targets individuals and businesses enabling Russia’s war in Ukraine, further constraining the networks and revenue streams on which the Kremlin relies. 

    Among the 19 targets sanctioned today are six Russian banks propping up its war economy, six newly acquired shadow fleet tankers responsible for dodging Western sanctions and four Russian companies importing tantalum and niobium, rare metals critical for producing military equipment used on the battlefield in Ukraine. 

    Foreign Secretary Ed Miliband said: 

    Today’s new sanctions demonstrate the UK’s unwavering commitment to supporting Ukraine and bearing down on those propping up the Kremlin’s aggression. 

    Ukraine’s fight is our fight. Those that threaten Ukraine’s freedom and democracy are a threat to Britain’s security at home. That’s why we will continue stepping up the pressure on Russia until a just and lasting peace has been reached.

    Today’s action further builds on the Foreign Secretary’s work on Ukraine since taking office. In recent weeks he has held his first bilateral call in the role with Foreign Minister Sybiha, attended the ASEAN conference in Manila where discussions focussed on support for Ukraine and joined the Prime Minister in Portsmouth last week to host President Zelenskyy, where the UK announced support for cutting-edge drone capabilities to bolster Ukraine’s frontline defences. 

    Yesterday the Foreign Secretary travelled to Washington DC where he met US Secretary of State Marco Rubio. Discussions focused on efforts to maintain pressure on Russia and underlined that Ukraine’s security is inseparable from European and transatlantic security.

    Chancellor John Healey MP said: 

    Our commitment to stand with the Ukrainian people is absolute. 

    That’s why we’re introducing new tougher sanctions to choke off the funds that fuel Putin’s illegal war and are targeting his shadow fleet. 

    And the UK will continue to step up our action against Russia and its shadow fleet activity to protect our national security, our economy, and global stability.

    This year alone the UK has imposed sanctions on over 500 individuals, entities and ships under its Russia sanctions regime, and today’s decisive action sends a clear signal that the UK will not let up on its efforts to hold Russia to account and support Ukraine for as long as it takes. 

    The UK government has now sanctioned over 3,400 individuals, entities and ships under the Russia sanctions regime. The latest measures form part of the UK’s ongoing effort to defend European and NATO security and weaken Russia’s ability to continue waging war in Ukraine. 

    Notes to editors: 

    Designations and specifications: 

    1. FRION SHIP MANAGEMENT LLP 
    2. NORTHERN ENGINEERING LIMITED LIABILITY COMPANY  
    3. IMO 9402263 (ASTERAS)   
    4. IMO 9326811 (PERSEAS)   
    5. IMO 9470131 (TORVIAN)   
    6. IMO 9378864 (VISUND)   
    7. IMO 9346885 (ZENTURO)    
    8. IMO 9333591 (ARCTIC EXPRESS) 
    9. LLC OZON BANK  
    10. JSC REALIST BANK  
    11. JSC TELEPORT BANK  
    12. PJSC BANK STAVR  
    13. PJSC COMMERCIAL BANK “CENTER-INVEST”  
    14. STATE SPECIALISED RUSSIAN EXPORT-IMPORT BANK (JSC)  
    15. LLC METALLKOMPLEKT   
    16. LLC NIKOM  
    17. LLC TECHNOLUX  
    18. LLC PROMSIZ  
    19. Alexander Aleksandrovich ZHDANOV

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  • August 4, 2026: Oops, says OFSI

    UK Gov logo, 50% resolution.png

    This e-alert is a re-issue of one published on Friday 31 July, which contained mismatches between the individuals’ names and UN IDs. The underlying data and change notice have not been changed. 

    Today, Friday 31 July, the UK Government has varied 5 designations under the Afghanistan Sanctions Regime. This reflects the decision to amend these designations made by the UN Security Council Sanctions Committee pursuant to Resolution 1988 (2011) on 30 July.

    Individuals Varied:

    Name:UN ID:Unique ID:
    Jalaluddin HAQQANITAi.144AFG0036
    Noor Mohammad SAQIBTAi.110AFG0088
    Hamdullah NOMANITAi.044AFG0039
    Abdul-Haq WASSIQTAi.082AFG0062
    Gul Agha ISHAKZAITAi.147AFG0115

    The original post, complete with Sanctions Notice, is here.

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  • Burning Questions; My Dinner with Claude – Strict Liability, Different Scales: OFAC and OFSI Compared

    My prompt:

    well, OFAC is also a strict liability regime – all who touch the transaction have violated the regulations, but the consequences, if any, vary according to the Enforcement Guidelines. So, OFAC just balances the scales differently, wouldn’t you say?

    Claude responded:

    Yes — and that’s a genuinely better way to put it than how it was left last message, so it’s worth correcting rather than defending the weaker version.

    The mechanics check out

    OFAC’s civil liability is strict: a violation exists the moment a blockable transaction occurs, full stop — OFAC need not prove fault or intent to bring an enforcement action and issue a civil penalty, and a civil penalty can be assessed even if the violator had no idea they were dealing with a sanctioned party. What actually happens next is calibrated entirely by the Enforcement Guidelines at 31 CFR Part 501, Appendix A — egregious versus non-egregious, voluntary self-disclosure, willfulness or recklessness, quality of the compliance program, awareness of the conduct, harm to program objectives. So the fault inquiry hasn’t been discarded, it’s just been relocated to the remedy stage instead of the liability stage. “Balances the scales differently” describes that far more precisely than the earlier “bets on speed vs. bets on accuracy” line, which overstated the contrast.

    And here’s the part that actually strengthens the parallel rather than just conceding it: the UK made exactly this same move. For breaches committed on or after 15 June 2022, OFSI can impose civil monetary penalties on a strict liability basis, regardless of the absence of knowledge or a reasonable cause to suspect — before that date, OFSI had to show knowledge or reasonable cause to suspect on the balance of probabilities. So the “we wait for fault before we act” framing offered earlier doesn’t even hold up as a clean description of the UK’s own penalty regime anymore. Knowledge and intent still matter there, but now as a severity factor within OFSI’s case assessment, not as a threshold for liability — the same architecture as OFAC’s General Factors.

    So where does the real difference actually live now?

    Not in whether fault matters — both regimes have converged on “fault affects the size of the punishment, not whether a violation occurred.” It survives in what strict liability is allowed to reach. OFAC’s fault-blindness attaches to an immediate, automatic property action: the money gets locked up the moment the objective trigger exists, and that seizure doesn’t reverse just because a later fault inquiry clears the customer — unblocking still requires its own separate license. The UK’s 2022 reform, notably, didn’t build an equivalent mechanism. It made it easier to fine someone for the underlying conduct without proving they knew — but it stopped there. It didn’t create a parallel power to seize Customer A’s payment while that question gets sorted out, because there’s still nothing belonging to the designated person to seize in Scenario A, for the reasons worked through earlier.

    That’s actually a more interesting finding than where things were left before: it isn’t that UK-style regimes are squeamish about strict liability in general — 2022 proves they aren’t. It’s that they’ve kept strict liability confined to punishing conduct after the fact, and never extended it into a mechanism for provisionally seizing an uninvolved party’s property before fault is even alleged. OFAC does both.

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  • July 31, 2026: OFSI updates Afghanistan designations

    UK Gov logo, 50% resolution.png

    Today, Friday 31 July, the UK Government has varied 5 designations under the Afghanistan Sanctions Regime. This reflects the decision to amend these designations made by the UN Security Council Sanctions Committee pursuant to Resolution 1988 (2011) on 30 July.

    Individuals Varied:

    Name:UN ID:Unique ID:
    Jalaluddin HAQQANI TAi.044AFG0036
    Noor Mohammad SAQIBTAi.082 AFG0088
    Hamdullah NOMANITAi.110 AFG0039
    Abdul-Haq WASSIQTAi.144AFG0062
    Gul Agha ISHAKZAI TAi.147AFG0115

    The Sanctions Notice:

    Sanctions_Notice__Afghanistan__31_July_2026Download

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  • Burning Questions; My Dinner with Claude – Six Countries, Two Wires: A Sanctions Compliance Cheat Sheet

    My prompt:

    ok… let’s open the aperture a bit. Explain what a compliant firm is supposed to do, for the US, UK, EU, Canada, Australia and Switzerland, in the following 2 scenarios – assuming we’re talking blocking/freezing sanctions only: Scenario A: You receive instructions to make a payment that involved a sanctioned party. Scenario B: You receive funds that involve a sanctioned party. For each scenario, also denote whether the answer is different in the case you are the beneficiary bank or an intermediary bank. Phrase this for a sanctions novice, but feel free to quote text (not full regulatory sections) – like “make economic resources available”, for example. Assume that my goal is to eventually, once I refine the response, make a “Burning Questions” post out of this

    Claude responded:

    This is exactly the kind of question that makes a good Burning Questions piece, because the honest answer isn’t “six jurisdictions, six rules” — it’s one rule almost everyone agrees on, and one narrow but consequential place where the US breaks from the rest.

    Two moves, and two roles, defined simply

    A compliant firm facing a sanctioned party has two different levers available, and confusing them is the single most common mistake:

    • Freeze/block: take the resource into your own custody, lock it away from everyone — including the customer who originally owned it — and report it. Nobody gets it until a regulator says otherwise.
    • Refuse/reject: simply decline to carry out the instruction. The money never leaves the paying customer’s account, so there’s nothing to freeze.

    And two roles matter for how this plays out:

    • Beneficiary bank: the bank holding the account of the person or entity who’s supposed to end up with the money.
    • Intermediary (correspondent) bank: a bank in the middle of the chain, routing the payment onward, with no account relationship to either the sender or the ultimate recipient.

    Scenario A: you receive instructions to make a payment that involves a sanctioned party

    Picture a customer who isn’t sanctioned asking you to send money to someone who is.

    JurisdictionWhat you doBeneficiary vs. intermediary bank
    US (OFAC)Block. Take the funds into a blocked, interest-bearing account. Don’t send them, and don’t hand them back to the customer either.No difference in principle — blocking applies regardless of whether it is the originating or intermediary bank in the chain. A purely blind intermediary with no account relationship to a non-listed related party gets a narrow pass on investigating what it has no way of knowing, but the moment it knows or should know a designated person is involved, it blocks too.
    UK (OFSI)Refuse. Don’t execute the payment; the customer’s own funds are untouched.Same principle for any bank in the chain — but correspondent banks caught mid-chain have created a genuine practical headache here (see below).
    EURefuse — going ahead would mean making economic resources available to the designated person, which every EU regulation prohibits directly or indirectly.Same in principle for whoever in the chain is asked to move the money.
    Switzerland (SECO)Refuse, for the same reason — Swiss ordinances closely mirror the EU wording, prohibiting third parties from making economic resources available to a listed person.Same in principle.
    CanadaRefuse — completing the payment would breach the ban on making any goods available to a designated person, or providing services to their benefit.Same in principle, though published Canadian guidance addressing intermediary banks specifically the way the US and UK have could not be located.
    Australia (DFAT/ASO)Refuse — a person commits an offence if they make assets available to a designated person or entity.Same in principle.

    The one country that flips the answer is the US, and it’s worth pausing on why. OFAC treats a designated person’s status as intended beneficiary of a payment as itself an “interest” in the funds, so the moment the firm has possession or control of the money for the purpose of sending it their way, it’s already blockable property — even though it started out as the customer’s own money and never actually reached anyone. Everyone else in this table requires the resource to actually belong to, or be held or controlled by, the designated person before the freeze duty exists — and a payment instruction that hasn’t been executed yet doesn’t meet that bar. So the divergence isn’t really about freeze versus reject as competing philosophies; it’s about how early each regime decides a sanctioned party has acquired an interest in money that hasn’t arrived yet.

    Scenario B: you receive funds that involve a sanctioned party

    Now flip it: money has actually arrived, or is already sitting in an account, where a designated person has a real, present interest — as the account holder, or as the completed beneficiary of an inbound transfer.

    JurisdictionWhat you doBeneficiary vs. intermediary bank
    US (OFAC)Block, and report within 10 business days.No difference — whoever’s possession or control the funds come within, blocks, subject to the same narrow intermediary safe harbor as above.
    UK (OFSI)Freeze, and report.The beneficiary bank freezes without question. An intermediary bank is generally fine to keep routing a payment onward provided the funds aren’t owned, held, or controlled by a designated person at the point it’s dealing with them — which gets complicated fast if a designated bank sat somewhere upstream (see below).
    EUFreeze, and report to the national competent authority. Notably, a bank is explicitly permitted to credit an incoming third-party payment into a frozen account without needing prior authorization for that specific act — the funds simply join the frozen pool once they land.Same logic as the UK: a true intermediary that never holds the designated person’s resources has nothing to freeze; a beneficiary bank freezes on receipt.
    SwitzerlandFreeze, and report to SECO.Same principle as the EU.
    CanadaFreeze (functionally, by disclosing the property to the RCMP and being barred from dealing with it) — firms must report property in their possession or control that is owned or controlled by designated persons and freeze such property.Same principle, applied to whoever holds it.
    AustraliaFreeze, and notify the Australian Federal Police.Same principle for whoever is holding the asset.

    This is really the headline finding: on receipt, all six jurisdictions land in the same place. The freeze duty is nearly universal once a designated person actually has a stake in the resource — the interesting divergence lives entirely in Scenario A, where the US alone extends that duty backward to cover an unexecuted instruction.

    Two wrinkles worth knowing for intermediary banks specifically

    US: OFAC’s own guidance draws the safe-harbor line precisely. An intermediary bank with no account relationship to a non-listed party referenced in a wire, and no actual or constructive knowledge of a blocking issue, isn’t expected to go digging — but the instant it has information suggesting blocked status, the duty to block attaches regardless of its position in the chain.

    UK: because the UK (unlike the EU generally) has designated entire banks, correspondent banks kept finding themselves holding payments that had passed through a now-designated bank somewhere upstream, with no clean way to either complete or return them — the industry calls these “trapped payments.” OFSI’s analysis turned on whether the designated bank still had a right of countermand over the funds at that point in the chain: if it had already discharged its role and lost any right to pull the funds back, the funds were no longer considered owned, held, or controlled by that designated bank, so the freeze duty didn’t travel downstream with it. That general licence has since been superseded by later amendments, so it’s an illustration of the reasoning rather than current operative guidance — worth pulling OFSI’s live Russia guidance before citing the mechanism itself.

    Self-check

    • US: OFAC FAQ 36 (reject example), FAQ 116 (intermediary safe harbor), and 31 CFR 501.603 (blocked-property reporting) pulled directly from ofac.treasury.gov.
    • EU: Regulation 36/2012 Article 14 template and the Council’s July 2024 Best Practices document, both previously verified.
    • UK: OFSI’s general guidance and reporting pages (gov.uk, ofsi.blog.gov.uk) plus the Trapped Payments general licence publication notice — flagged above as superseded, useful for the reasoning, not for current citation.
    • Canada: Global Affairs Canada’s own “Dealings prohibition and asset freeze” and disclosure pages — solid primary sourcing, but nothing found specific to intermediary-bank treatment; that’s a gap in published guidance, not a claim made by extension.
    • Australia: DFAT/Australian Sanctions Office guidance notes, all primary and current (2024–2025 dated).
    • Switzerland: sourced mainly through a Swiss press account describing the ordinance language rather than a direct ordinance or SECO FAQ pull — worth swapping in the exact ordinance article, and worth checking whether SECO’s FAQs address this reject/freeze point directly before publishing.
    • The “when does an interest attach” framing that ties the whole piece together is an original synthesis of the sourced material above, not a line any one source states outright.

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  • July 24, 2026: How to tell if you’re talking to OFSI (or not)

    Office of Financial Sanctions Implementation HM Treasury

    New guidance on verifying communications claiming to be from OFSI 

    OFSI has published new guidance on how to verify whether communications claiming to be from OFSI are genuine. 

    The guidance provides information to help individuals verify communications claiming to be from OFSI, including signs that a communication may not be genuine and sets out what to do if you are unsure. 

    The guidance:

    Check if an email or communication claiming to be from OFSI is genuine

    OFSI will never ask you to make a payment, transfer cryptocurrency, pay a fee to obtain a licence, or pay to release frozen funds. 

    1.  I’ve received a suspicious email or communication claiming to be from OFSI. What should I do? 

    If you receive a suspicious communication claiming to be from OFSI, HM Treasury or another government body: 

    • do not reply 
    • do not click any links or open attachments 
    • do not make any payments 
    • do not use the contact details they have provided 

    Instead, use the official contact details published on GOV.UK. If you’re unsure if a communication is genuine, contact OFSI directly at ofsi@hmtreasury.gov.ukimmediately. 

    2. How to check if an OFSI email or letter is genuine  

    Official OFSI emails are sent from: 

    Official UK government email addresses end in ‘gov.uk’. Always check the full email address carefully. 

    Scammers may use email addresses or display names that appear to come from a UK government department. 

    They may also use official-looking documents, branding, formatting or language to make communications appear genuine. A professional-looking email or letter does not mean it is authentic. 

    3. Does OFSI contact people by text message or WhatsApp? 

    No, OFSI will never contact you via: 

    • Text message  
    • WhatsApp 

    If you receive a message claiming to be from OFSI through these channels, you should treat it as suspicious.  

    4.  Signs an OFSI communication may be a scam 

    Be cautious if a communication claiming to be from OFSI: 

    • Asks you to pay a fee for an OFSI licence application. Applications for OFSI licences are made through the official GOV.UK website and there is no charge to apply for a licence   
    • Asks you to send or transfer money, cryptocurrency, or make a payment to unfreeze funds or release assets. OFSI does not require individuals to transfer money or cryptocurrency to obtain a licence, release frozen funds or assets, avoid enforcement action, or verify compliance with UK financial sanctions. Funds are frozen by relevant persons, such as banks, in accordance with UK sanctions legislation. Payment to OFSI, a bank or a third party will not unfreeze funds. 
    • Asks you to provide personal, banking or financial information. Genuine OFSI communications will not ask you to provide sensitive financial information or security credentials unexpectedly. If you are unsure whether a communication is genuine, contact OFSI directly using the contact details published on GOV.UK.  
    • Pressure you to make an immediate payment to avoid fines, penalties or other consequences. Communications that demand urgent payment or threaten enforcement action if you do not pay should be treated with caution. 

    5.  Report a scam or phishing email 

    If you believe you have received a scam or phishing email claiming to be from OFSI, you can report it to the National Cyber Security Centre.

    If you’ve been a victim of a scam, suffered financial loss or responded to a scam communication, report it to Report Fraud through their website or to Police Scotland by calling 101 if you live in Scotland.  

    You can report fraud to Report Fraud if you are in the UK, if the fraud occurred in the UK or if the fraud is related to the UK and the internet. Report Fraud also provides information on reporting fraud in a range of languages and guidance for people who may need support accessing its services. 

    If you live outside the UK, you can also report it to your local law enforcement agency or the relevant fraud reporting authority in your country.

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  • July 24, 2026: OFSI adds the vessel the UN added to Libya sanctions

    UK Gov logo, 50% resolution.png

    Today, Friday 24 July, the UK Government has specified 1 vessel under the Libya Sanctions Regime. This reflects the decision to specify the vessel made by UN Security Council Sanctions Committee pursuant to Resolution 1970 (2011).

    Specified Vessel:

    Name:UN ID:Unique ID:
    IMO 9058713 (“AVAX”)Lye.006LIB0079

    The Sanctions Notice:

    Sanctions_Notice__Libya__24_July_2026Download

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  • July 23, 2026: OFSI adds 2, amends 1 Russian sanctions designations

    UK Gov logo, 50% resolution.png

    Today, Thursday 23 July, the UK Government has varied 2 designations and made 1 amendment, all sanctioned under the Russia Sanctions Regime.

    Varied Individuals:

    Name:Unique ID:
    Pavel EZUBOVRUS1333
    Vasily Vitalyevich ABRAMOVRUS2397

    Amended Individual:

    Name:Unique ID:
    Daria Sergeevna ROSLIAKOVARUS3697

    The Sanctions Notice:

    Sanctions_Notice__Russia__23_July_2026Download

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  • Burning Question: Pulling BNA out of the FAQs

    The prompt:

    Summarize UK sanctions regulations and exemptions regarding Basic Needs Allowance, including any relevant definitions, in light of today’s FAQs, attached here. plesse provide your response for an audience of non-UK sanctions professonals who are not lawyers.

    The final response:

    The legal architecture beneath BNA

    Primary legislation. The Sanctions and Anti-Money Laundering Act 2018 (SAMLA, 2018 c.13) is the enabling statute for essentially all post-Brexit UK sanctions. It doesn’t itself list licensing grounds – it authorises Treasury/the Secretary of State to make regime-specific secondary legislation.

    Regime-specific regulations. Each sanctions regime (Russia, Iran, Syria, Belarus, Chemical Weapons, and so on) has its own statutory instrument made under SAMLA – for example the Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855). Each of these includes a schedule titled “Treasury licences: purposes,” which is the actual legal source of each licensing ground. I confirmed this schedule structure directly: in the Chemical Weapons (Sanctions) (EU Exit) Regulations 2019 (SI 2019/618), Schedule 2, paragraph 2, “Basic needs” reads almost exactly as you’d expect:

    To enable the basic needs of a designated person, or (in the case of an individual) any dependent family member of such a person, to be met.

    For individuals, it lists medical needs, food, insurance premiums, tax, rent or mortgage, and utility payments as included needs. The Russia Regulations carry the equivalent ground at Schedule 5, paragraph 2, though I wasn’t able to pull the exact Russia-specific wording (only confirmed its existence and paragraph position via secondary indices) – the substance is consistent across regimes but the schedule number and paragraph numbering differ regime to regime, so it’s worth checking the specific regulation rather than assuming identical numbering.

    Where basic needs sits among the other grounds. Per OFSI’s own “How to apply for a financial sanctions licence” guidance, the generally available licensing grounds are:

    • basic needs
    • legal fees and expenses
    • prior obligations (pre-designation contracts)
    • routine holding or maintenance of frozen funds/economic resources
    • implementation of a judicial, administrative, or arbitral decision or lien
    • post-designation judicial decisions (non-UN designations only)
    • extraordinary expenses
    • extraordinary situations (non-UN designations only)
    • humanitarian assistance
    • diplomatic missions
    • insolvency
    • divestment

    That page also confirms the general/specific licence mechanics I described earlier: general licences are issued by OFSI at its own initiative for a defined class of activity, and OFSI does not accept applications for them – you either fall within one or you apply for a specific licence.

    The direct throughline to BNA

    This is the most useful find. OFSI’s “Designated Individuals Licensing Principles” (a policy document sitting under the General Guidance, last updated 2 February 2026) already contained a formal benchmark for basic needs, at Principle 4:

    Licensing should permit basic needs, which OFSI considers to include the reasonable standard of living as compared to a person receiving the net UK median wage.

    And Principle 4(a): “Ordinarily, Principle 4 will be generally satisfied by granting a designated individual the net UK median wage.”

    That’s a striking match to today’s BNA FAQs, with one difference worth flagging as a genuine shift rather than a restatement: the February principle benchmarks to the net UK median wage (an individual figure), while today’s FAQ benchmarks to a median income household. A household benchmark is not the same number as an individual wage benchmark – it implicitly accounts for household composition and dependents in a way a flat wage figure doesn’t. I can’t tell you from the FAQ text alone whether that’s a deliberate policy refinement or just looser drafting, but it’s the kind of distinction worth watching for in OFSI’s next General Guidance update, since it would change the actual capped amount a DP receives.

    Historical background, clearly caveated as background rather than confirmed lineage: In 2023, litigation against OFSI (Fridman v HMT, the first challenge to an OFSI licensing decision under the Russia Regulations) resulted in disclosure of a previously secret internal “Basic Needs Framework,” which split basic needs into “core needs” (proposed to be met by a flat monthly sum pegged to median wage) versus needs beyond that. The High Court dismissed the claim and confirmed OFSI retains “residual discretion to refuse to grant a licence, even if the conditions for the grant of a licence are met” – a principle that reappears in today’s FAQ as “compliance with those conditions does not guarantee that a licence will be renewed or varied.” Commentators at the time (Law Gazette, November 2023) explicitly called for OFSI to formalise exactly this kind of standing monthly allowance rather than handling it case by case. I can’t point to a document that explicitly says “BNA is the formalisation of the Basic Needs Framework” – but the throughline from the 2023 disclosure, to the February 2026 Designated Individuals Licensing Principles, to today’s FAQ is consistent enough that I think it’s a fair inference, not a stretch.

    A limitation worth being upfront about

    I tried to independently verify FAQs 197-202 on OFSI’s live FAQ page. The version I could retrieve carries a “last updated” stamp of 29 May 2026, predating your attachment’s 21 July 2026 date – so I couldn’t cross-check the exact text against a live, independently-fetched copy; I’m relying on your attachment as the primary source for the BNA-specific content itself. What I can confirm independently is that the FAQ numbering, format, and “Added on:” convention in your document are consistent with OFSI’s genuine, ongoing FAQ series (which runs to at least FAQ 186 in the version I retrieved), so the document is stylistically and structurally what it claims to be – I just can’t yet corroborate the specific new entries from a second, independent live source.

    Source list

    Primary legislation and regulations

    • Sanctions and Anti-Money Laundering Act 2018 (c.13) – legislation.gov.uk/ukpga/2018/13
    • Chemical Weapons (Sanctions) (EU Exit) Regulations 2019 (SI 2019/618), Schedule 2, para 2 (“Basic needs”) – legislation.gov.uk/uksi/2019/618/schedule/2/paragraph/2/data.html
    • Russia (Sanctions) (EU Exit) Regulations 2019 (SI 2019/855), regulation 64 and Schedule 5 – legislation.gov.uk/uksi/2019/855/regulation/64

    OFSI guidance and policy

    • OFSI, “How to apply for a financial sanctions licence” (last updated 1 September 2025) – gov.uk/guidance/licences-that-allow-activity-prohibited-by-financial-sanctions
    • OFSI, “UK Financial Sanctions FAQs” (updated 29 May 2026 as retrieved) – gov.uk/government/publications/uk-financial-sanctions-faqs/uk-financial-sanctions-faqs
    • OFSI, “Designated Individuals Licensing Principles” (updated 2 February 2026) – gov.uk/government/publications/financial-sanctions-licensing/ofsi-licensing-designated-individuals-licensing-principles–2
    • OFSI, “UK financial sanctions general guidance” (updated 28 January 2026) – gov.uk/government/publications/financial-sanctions-general-guidance/uk-financial-sanctions-general-guidance
    • OFSI Blog, “OFSI successfully defends first court review” (Fridman v HMT) – ofsi.blog.gov.uk/2023/11/28/ofsi-successfully-defends-first-court-review

    Commentary (context on the pre-BNA “Basic Needs Framework”)

    • Law Gazette, “Sanctions: Time for a general licence to cover basic needs” (13 November 2023) – lawgazette.co.uk/practice-points/time-for-a-general-licence-to-cover-basic-needs/5117856.article
    • Corker Binning, same title/content (23 September 2024 mirror) – corkerbinning.com/time-for-a-general-licence-to-cover-basic-needs

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  • July 21, 2026: OFSI adds 6 new FAQs on BNAs

    Office of Financial Sanctions Implementation HM Treasury

    6 FAQs added on Basic Needs Allowance (BNA)

    OFSI has published FAQs 197-202 on Basic Needs Allowance (BNA) licences, which permit designated persons to access a capped monthly sum from frozen funds for essential living expenses. OFSI benchmarks the BNA against median household income. In many cases, including those involving high net worth individuals, the BNA will not provide for the continuation of a pre-designation standard of living.

    FAQs 197-202 cover the purpose and scope of BNA licences, permitted expenditure, reporting requirements, treatment of monthly underspend, and how costs falling outside the BNA may be licensed separately.

    The guidance is relevant to designated persons and any party facilitating payments under a BNA licence.

    The FAQs:

    Basic Needs Allowance

    197. What is a basic needs allowance licence?

    A Basic Needs Allowance (BNA) licence is a type of specific licence which OFSI may issue under the basic needs licensing ground across all non-counter-terrorism sanctions regimes. It permits a designated person (DP) to access a capped monthly sum from their otherwise frozen funds to meet essential day-to-day living expenses. OFSI benchmarks the allowance to reflect a median income household rather than the DP’s previous lifestyle or claimed expenditure.  Rent or mortgage payments are considered separately from the BNA and assessed on a case-by-case basis.

    Added on: 21 Jul 2026

    198. What is the purpose of the basic needs allowance?

    The basic needs allowance is intended to help ensure that a DP and any financially dependent family members can meet their day-to-day living costs, broadly in line with a median-income household. It is not intended to enable a DP to maintain the lifestyle, wealth, or business activities they enjoyed prior to designation.

    DPs applying for or operating under a BNA licence should ensure that expenditure remains consistent with this purpose. Any party facilitating payments under a BNAlicence should similarly satisfy itself that the payments fall within the terms and purpose of the licence.

    Added on: 21 Jul 2026

    199. Do basic needs allowance licences include reporting requirements?

    Yes. Basic needs allowance licences include reporting conditions requiring expenditure to be evidenced and reported to OFSI. This is a proportionate method that enables OFSI to maintain oversight of the usage of the licence and may inform any future decision when licences are renewed or varied.

    Applicants should be prepared to comply with any reporting requirements imposed as conditions of a licence. Compliance with those conditions does not guarantee that a licence will be renewed or varied.

    Added on: 21 Jul 2026

    200. What can the basic needs allowance be spent on?

    OFSI does not provide an exhaustive list of approved purchases. A DP has broad discretion, though not total, in how the allowance is used. That discretion is limited by the terms of the licence, the relevant sanctions regulations, and the purpose for which the licence is granted

    The allowance is intended to cover goods and services that reasonably constitute basic needs. This may include (but is not limited to) food, clothing, personal hygiene, local transport, basic household items, and hairdressers. It does not cover expenditure that falls outside the terms of the basic needs licencing purpose, nor expenditure which would otherwise breach the financial sanction’s regime.  

    Some discretionary spending may be consistent with the terms of a BNA where it supports basic family life and remains proportionate to the benchmark of a median-income household. This may include recreation, education, leisure, and other miscellaneous goods and services. Whether such expenditure is appropriate will depend on the circumstances and must remain consistent with the purpose of the licence.

    Added on: 21 Jul 2026

    201. Does the basic needs allowance licence permit carry-over of any monthly underspend?

    No. Each month’s allowance is a fixed, standalone cap. If a DP does not use the full allowance in a given month, the unspent amount cannot be carried forward or added to the following month’s allowance. The monthly cap resets at the start of each new month.

    Added on: 21 Jul 2026

    202. Does OFSI license costs separately that may fall outside of the core basic needs allowance?

    Yes. Where a cost cannot reasonably be met from the basic needs allowance, OFSI may consider a separate licence application. Such applications are assessed on their individual merits and approval is not automatic.

     OFSI will consider whether the relevant cost could reasonably be met from within the basic needs allowance. In particular, OFSI will assess whether the expenditure is of a type that a median-income household would ordinarily absorb through routine day-to-day spending.

    Where a cost could reasonably be met from the basic needs allowance, OFSI would generally expect it to be funded from that allowance rather than licensed separately.

    Applicants seeking separate licensing should therefore explain why the expenditure cannot reasonably be met from the basic needs allowance, how the relevant licensing purpose is met, and provide supporting evidence where appropriate. Applications can be submitted via OFSI’s application form at: OFSI launches online forms for reporting and licences – Office of Financial Sanctions Implementation.

    Added on: 21 Jul 2026

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