Mr. Sanctions

Category: Frequently Asked Questions (FAQs)

  • Burning Questions: Outside the US, Beyond the letter of regulation

    The prompt:

    Outside the US, what governments issue sanctions-related guidance, advisories, frequently-asked questions and other publications which clarify sanctions legislation and regulation? pease describe the types of publications and their level of detail and specificity for each government, and compare and contrast each country’s set of such documents, Do not limit yourself to English-language texts. And please quote all sources, with URLs when available.

    The response:

    The United States (via OFAC) is often viewed as the “gold standard” for volume and specificity of sanctions guidance. However, owing largely to the complex sanctions landscape post-2022 (Russia/Ukraine), other major economies have rapidly developed their own detailed interpretive infrastructure.

    The following is an analysis of non-US government publications that clarify sanctions legislation, organized by jurisdiction.

    1. United Kingdom: Office of Financial Sanctions Implementation (OFSI)

    Since Brexit, the UK has developed a sanctions infrastructure that rivals the US in complexity and specificity. OFSI is the primary issuing body.

    • Types of Publications:
      • General Guidance: The “Standard Bearer” document. It covers the UK’s definition of ownership and control, licensing processes, and reporting obligations.
      • Sector-Specific Guidance: Detailed guidance for Maritime shipping (oil price cap), Charity/NGOs, and Financial Services.
      • FAQs: Extensive Q&A covering specific regulations (especially the Russia regulations).
      • Blog/Alerts: OFSI uses its blog to publish “Red Alerts” on evasion typologies (e.g., gold, artwork).
      • General Licences: Unlike the US, the UK publishes “General Licences” (GLs) with accompanying explanatory notes that act as effectively binding guidance on what is permitted.
    • Level of Detail & Specificity: High.OFSI provides very specific interpretive guidance. For example, they define “ownership and control” in granular detail (e.g., examining “dominant influence” over a board of directors). They are one of the few bodies outside the US that publishes enforcement actions (monetary penalties) which serve as case-law-like guidance for the industry.
    • Source: OFSI General Guidance and FAQs

    2. European Union: European Commission & Council of the EU

    The EU issues sanctions at the bloc level, but enforcement is done by member states. To ensure uniformity, the Commission has become extremely prolific in issuing interpretive guidance.

    • Types of Publications:
      • Consolidated FAQs: The primary vehicle for EU guidance. Since 2022, the Commission has published hundreds of pages of FAQs specifically on the Russia/Belarus regimes.
      • “Best Practices” Guidelines: High-level documents from the Council of the EU detailing how to implement asset freezes or identifying beneficial ownership.
      • Commission Opinions: Formal legal opinions on how to interpret specific articles of Council Regulations (e.g., whether “transfer” of goods includes transit).
    • Level of Detail & Specificity: High (but Legalistic).EU guidance is often drafted by lawyers for lawyers. It focuses heavily on statutory interpretation (e.g., “Does Article 5aa prohibit X?”). It is less operational than US/UK guidance but provides definitive answers on scope, such as the exact calculation of “50% ownership” and whether it applies to aggregation of shares.
    • Source: European Commission Sanctions FAQs

    3. Australia: Department of Foreign Affairs and Trade (DFAT) & Australian Sanctions Office (ASO)

    Australia has moved toward a user-friendly, toolkit-based approach for the private sector.

    • Types of Publications:
      • Sanctions Compliance Toolkit: A consolidated PDF designed for businesses/universities to build their own compliance programs.
      • Guidance Notes: Thematic papers on specific high-risk sectors (e.g., “Conflict Minerals,” “Maritime Shipping,” “Ransomware”).
      • Advisory Notes: Alerts on specific evasion risks.
    • Level of Detail & Specificity: Medium.Australia’s guidance is excellent on process (how to assess risk, how to apply for a permit) but arguably offers fewer specific interpretive rulings on complex financial scenarios than the UK or EU. It relies heavily on “due diligence” principles rather than prescriptive rules.
    • Source: Australian Sanctions Office Guidance Notes

    4. Canada: Global Affairs Canada (GAC)

    Historically, Canada provided very little guidance beyond the legislative text. This has changed significantly in recent years with the release of formal interpretive documents.

    • Types of Publications:
      • Sanctions Guidance: A formal document released to clarify “Deemed Ownership” (a unique Canadian concept where any entity in a sanctioned country might be “deemed” owned by that state).
      • Thematic Guidance: Specific papers for the Financial Sector and Academic/Research Sector.
      • Sanctions Notices: Updates notifying the public of new listings.
    • Level of Detail & Specificity: Medium-Low.While improving, Canada’s guidance is often broader and less scenario-based. For example, while the definition of “property” is clarified, the specific application to complex financial instruments is often left to the “judgment” of the operator compared to the detailed FAQs of the EU.
    • Source: Global Affairs Canada Sanctions Guidance

    5. Japan: Ministry of Finance (MOF) & METI

    Japan’s guidance differs culturally; it is often integrated into broader trade control and anti-money laundering (AML) frameworks rather than standing alone as “sanctions guidance.”

    • Types of Publications:
      • Trade Control Policy (METI): Detailed lists of controlled items and end-user lists (the “Foreign End User List”) which function as de facto sanctions lists.
      • AML/CFT Guidelines (JFSA/MOF): Guidelines for financial institutions that include sections on asset freezing and screening.
      • Q&A on Foreign Exchange and Foreign Trade Act: Technical Q&A on how to process payments to sanctioned jurisdictions.
    • Level of Detail & Specificity: High (Technical).The guidance is highly technical regarding trade classifications (goods codes) and payment processing permissions. It is less focused on “sanctions evasion typologies” in the Western sense and more on administrative compliance with the Foreign Exchange and Foreign Trade Act.
    • Source: METI Security Export Control Q&A (Japanese/English)

    6. Singapore: Monetary Authority of Singapore (MAS)

    Singapore issues sanctions guidance strictly through its financial regulator, focusing on Financial Institutions (FIs).

    • Types of Publications:
      • MAS Regulations & Notices: Legally binding notices prohibiting transactions with specific countries (e.g., DPRK, Iran, Russia).
      • “Red Flag” Indicators: Publications highlighting suspicious transaction indicators related to proliferation financing or sanctions evasion.
      • FAQs: Specific Q&As for Financial Institutions regarding asset freezing implementation.
    • Level of Detail & Specificity: Medium.The guidance is precise but narrow; it targets FIs almost exclusively. It is highly specific regarding the mechanics of freezing funds but offers less guidance for non-financial corporates (e.g., exporters, manufacturers) compared to the EU or UK.
    • Source: MAS Targeted Financial Sanctions

    Comparative Analysis

    FeatureUK (OFSI)EU (Commission)Australia (ASO)Canada (GAC)Japan (METI/MOF)
    Primary FocusFinancial & Trade interpretationLegal interpretation for Member StatesCompliance process & Risk AssessmentLegislative clarificationTrade control & Admin procedure
    FormatDetailed General Guidance + Blog AlertsMassive Consolidated FAQs“Toolkit” & Thematic NotesThematic WebpagesTechnical Q&A & End-User Lists
    “Control” Defined?Yes (Very detailed tests)Yes (Detailed criteria)Yes (General principles)Yes (“Deemed ownership”)Implicit(subsidiary rules)
    Scenario SpecificityHigh (e.g., Crypto, Maritime)High (e.g., Transit, IP rights)Medium (Sectoral risks)Low-MediumHigh (Product specs)
    ToneCollaborative but strictLegalistic / FormalEducational / PracticalAdvisoryAdministrative / Bureaucratic

    Summary for the User

    • If you need US-style detail: Look to the UK (OFSI) and EU. They are the closest to providing “answers” to specific hypothetical scenarios.
    • If you need to build a program: Australia’s “Toolkit” is one of the best structural guides for how to set up compliance, regardless of jurisdiction.
    • If you are in Trade/Manufacturing: Japan (METI) and EU guidance provide the most detail on controlled goods codes and transit.

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  • February 2, 2026: and U? Yet another new version of Venezuela GL 5 (and an updated FAQ, too)

    This is the General License (GL) that authorizes transactions on PDVSA’s (Petróleos de Venezuela SA) 8.5% bond after a specified date… which this version pushes back another 6 weeks or so:

    venezuela_gl5u_0Download

    and the related Frequently Asked Question (FAQ) was updated, too:

    595. What does Venezuela-related General License 5U authorize?

    The President issued Executive Order (E.O.) 13835 on May 21, 2018. Subsection 1(a)(iii) of E.O. 13835 prohibits U.S. persons from engaging in transactions related to the sale, transfer, assignment, or pledging as collateral by the Government of Venezuela (GOV) of any equity interest in an entity owned 50 percent or more by the GOV. One effect of subsection 1(a)(iii) is to require authorization before U.S. persons may engage in certain transactions regarding any equity interest in an entity owned 50 percent or more by the GOV. Subsequent to the issuance of E.O. 13835, OFAC received inquiries about how and whether subsection 1(a)(iii) of E.O. 13835 could affect the ability to enforce bondholder rights to the CITGO shares serving as collateral for the Petróleos de Venezuela, S.A. (PdVSA) 2020 8.5 percent bond. OFAC issued General License (GL) 5 on July 19, 2018, which removed E.O. 13835 as an obstacle to holders of the PdVSA 2020 8.5 percent bond gaining access to their collateral.

    General License 5 was replaced and superseded by General License 5A on October 24, 2019 with a delay in the effectiveness of the authorization in the general license. Since that date, OFAC has extended the delay in effectiveness multiple times. Most recently, OFAC issued General License 5U on February 2, 2026, which further delays the effectiveness of the authorization in GL 5 until March 20, 2026. Between October 24, 2019 and March 20, 2026 (the date the authorization in General License 5U becomes effective), there is no authorization in effect that licenses against subsection 1(a)(iii) of E.O. 13835 applicable to the holders of the PdVSA 2020 8.5 percent bond. As a result, during such period, transactions related to the sale or transfer of CITGO shares in connection with the PdVSA 2020 8.5 percent bond are prohibited, unless specifically authorized by OFAC.

    To the extent an agreement may be reached on proposals to restructure or refinance payments due to the holders of the PdVSA 2020 8.5 percent bond, additional licensing requirements may apply. OFAC would encourage parties to apply for a specific license and would have a favorable licensing policy toward such an agreement.

    Date Updated: February 2, 2026

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  • Price Drop! UK Lowers the Russian Oil Price Cap

    Office of Financial Sanctions Implementation HM Treasury

    UK Lowers Oil Price Cap on Seaborne Russian Crude Oil

    Today, the UK, alongside the EU, has announced that the Oil Price Cap on seaborne Russian Crude Oil will be lowered from $47.60 to $44.10 per barrel. The lowered Oil Price Cap of $44.10 per barrel comes into effect at 23:01 (GMT), Saturday, 31 January 2026. 

    This action will maintain regulatory alignment in targeting Russian revenues and is part of the UK’s ongoing commitment to supporting Ukraine in its struggle against Russia’s illegal war of aggression. 

    This will apply to all services captured by the Oil Price Cap, including maritime transportation and the provision, directly, or indirectly, of brokering services or financial services or funds, related to the maritime transport of Russian crude from a place in Russia to third countries or from one third country to another.  

    For any trades with an effective date of contract before 23:01 (GMT), Saturday, 31 January 2026 and which are compliant with the existing price cap of $47.60 per barrel, there will be a wind-down ending at 22.59 (BST), Thursday, 16 April.  After the wind-down, the lower price cap of $44.10 per barrel takes effect. This measure is necessary to give UK businesses the required time to adjust and ensure the consistent implementation of the price cap by all operators.  

    OFSI has updated FAQs 154-161 today to support industry in adapting to the lower price cap over the wind-down period. Market participants must comply with the usual reporting and attestation requirements imposed by the Oil Price Cap General Licence. 

    To read OFSI’s FAQs, click here

    For the updated Oil Price Cap general licence, click here
     
    For OFSI’s full Oil Price Cap guidance, click here

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  • December 14, 2025: New Version of Russia-related GL 131, and updated FAQs

    Today, OFAC issued Russia-related General License 131B – identical to 131A, except that the expiration date got moved to end of February.

    russia_gl131bDownload

    Two Frequently Asked Questions got updated – 1224:

    1224. What negotiations does Russia-related General License 131B authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

    and 1225:

    1225. What activities do Russia-related General License 128B and General License 131B authorize related to Lukoil International GmbH (LIG)?

    Both were changed to refer to the new version of the GL, of course.

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  • Useful Resources: EU Russia-related sanctions FAQs (English version)

    As of today, this is located here (the Special Economic Zones section is recent):

    faqs-sanctions-russia-consolidated_enDownload

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  • January 6, 2026: New version of Russia-Related GL 13 + updated FAQs

    Today’s OFAC Action includes the publication of Russia-Related General License 13P, which extends the expiration date of the GL from January 9th to April 9th:

    russia_gl13pDownload

    OFAC also updated two Frequently-Asked Questions (FAQs) to refer to the new version of the GL – 999:

    999. What authorizations exist for entities subject to Directive 4 under Executive Order (E.O.) 14024, “Prohibitions Related to Transactions Involving the Central Bank of the Russian Federation, the National Wealth Fund of the Russian Federation, and the Ministry of Finance of the Russian Federation,” as amended (Russia-related Sovereign Transactions Directive)?

    and 1118:

    1118. As of December 2022, the Government of the Russian Federation may require a so-called “exit tax” payment prior to the divestment of assets located in the Russian Federation, potentially requiring transactions involving the Central Bank of the Russian Federation or the Ministry of Finance of the Russian Federation. Do U.S. sanctions prohibit the payment of this so-called “exit tax”? Does Russia-related General License (GL) 13P authorize transactions that involve the payment of this exit tax?

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  • December 19, 2025: OFAC adds Maduro family & associates to SDN List, plus updated GL and FAQ

    Based on the OFAC Notice and related press releases for December 19, 2025:

    Venezuela-related Designations; Issuance of Venezuela-related General License; Publication of Amended Venezuela-related Frequently Asked Question

    Treasury Press Release: Treasury Targets Family Members and Associates of Maduro Regime

    Additions:

    VENEZUELA-EO13850 Executive Order 13850

    CARRETERO NAPOLITANO, Roberto, Panama; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: CARRETERO NAPOLITANO, Ramon).

    CARRETERO NAPOLITANO, Vicente Luis, Panama; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: CARRETERO NAPOLITANO, Ramon).

    FLORES DE MALPICA, Eloisa, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    HURTADO PEREZ, Damaris del Carmen, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA FLORES, Iriamni, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA HURTADO, Erica Patricia, Venezuela; Gender Female; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    MALPICA TORREALBA, Carlos Evelio, Venezuela; Gender Male; Secondary sanctions risk: section 1(b) of Executive Order 13224, as amended by Executive Order 13886; (individual) [VENEZUELA-EO13850] (Linked To: MALPICA FLORES, Carlos Erik).

    Supplemental Information: The Treasury Department designated these seven individuals for their roles as family members and associates helping to sustain the narco-corruption structure of the Maduro regime. Specifically, the action targets the networks of Carlos Erik Malpica Flores (a nephew of Cilia Flores and former official at PDVSA and the Venezuelan Treasury) and Panamanian businessman Ramon Carretero Napolitano. Eloisa Flores de Malpica is the mother of Carlos Erik Malpica Flores and sister of Cilia Flores. Carlos Evelio Malpica Torrealba is his father, Iriamni Malpica Flores is his sister, Damaris del Carmen Hurtado Perez is his wife, and Erica Patricia Malpica Hurtado is his adult daughter. Roberto and Vicente Luis Carretero Napolitano are immediate family members of Ramon Carretero. Malpica Flores has been previously sanctioned and linked to corruption within Venezuela’s state-run oil company, PDVSA.

    You can learn more about the sanctions process in this video: OFAC Sanctions List Search tool which explains how to verify designated individuals.

    Additionally, we have a new version of GL 5:  Venezuela-related General License 5T, “Authorizing Certain Transactions Related to the Petróleos de Venezuela, S.A. 2020 8.5 Percent Bond on or After February 3, 2026.” As usual, the date at which you can deal in the bond has been pushed out – now it’s February 3rd of next year.

    And the related Frequently Asked Question – FAQ 595 – has been updated to reflect the new GL version and the new date.

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  • OFAC Amends two Russia-related FAQs

    As per the OFAC Notice:

    Issuance of Amended Russia-related Frequently Asked Questions

    Release Date

    12/18/2025

    Recent Actions Body

    OFAC is issuing two amended Russia-related Frequently Asked Questions, FAQ 1224 and 1225.

    The FAQs:

    1224. What negotiations does Russia-related General License 131A authorize, and what transaction conditions will OFAC consider when evaluating requests for further authorization to effectuate a sale of Lukoil International GmbH (LIG) assets?

    Answer

    On October 22, 2025, OFAC designated PJSC Lukoil (Lukoil) to increase pressure on Russia’s energy sector and degrade Russia’s ability to raise revenue for its war machine.  OFAC is aware of potential efforts by Lukoil to divest its assets outside of Russia to non-blocked parties, given the impact of sanctions.  To support such divestments and further cut off funding to Russia, OFAC issued Russia-related General License (GL) 131A, which authorizes negotiations and entry into contingent contracts with Lukoil for the sale of LIG or any of LIG’s majority-owned subsidiaries.  Authorized activities include negotiations on terms for definitive agreements and financial, legal, or operational due diligence, including engagement of outside counsel or advisors.  GL 131A expires on January 17, 2026.

    GL 131A does not authorize transactions to effectuate the actual sale, disposition, or transfer of any LIG entity or asset.  Any contract entered into pursuant to GL 131A must expressly be made contingent upon the receipt of a separate authorization from OFAC.  The goal of OFAC’s Russia sanctions is to place pressure on Moscow to end its war. 

    As such, Treasury would evaluate any proposed sale of LIG based on factors that support U.S. national security and foreign policy objectives.  OFAC expects that, at a minimum, the proposed transaction must:  completely sever LIG’s ties with Lukoil; block any funds owed to Lukoil until sanctions are lifted by placing them in an account subject to U.S. jurisdiction; and not provide a windfall to Lukoil, such as by providing up-front value to Lukoil, including through asset or share swaps.  Further, as a condition of any future license for effectuating a sale of LIG, OFAC expects that it will require persons purchasing LIG’s assets to seek OFAC review before further divestment of material LIG assets.

    OFAC may revoke GL 131A at any time, including if Lukoil and LIG do not appear to be engaging in good faith negotiations regarding the divestment of LIG or its assets.

    Date Updated: December 18, 2025

    Date Released

    November 19, 2025

    and:

    1225. What activities do Russia-related General License 128B and General License 131A authorize related to Lukoil International GmbH (LIG)?

    Answer

    OFAC has issued two General Licenses (GLs) relating specifically to Lukoil International GmbH (LIG) and its majority-owned subsidiaries (“LIG Entities”):  GL 128B and GL 131A.  The GLs are similar but have different expiration dates and terms as each serves a different purpose.  

    • To mitigate the effects of Lukoil’s OFAC designation on retail consumers, OFAC issued on December 4, 2025 GL 128B to authorize maintenance, operation, and wind down activities for a narrow range of LIG entities, specifically Lukoil retail automobile service stations outside of the Russian Federation.  This GL expires on April 29, 2026.
    • To enable Lukoil to divest its assets outside of Russia to non-blocked parties, OFAC issued on December 10, 2025 GL 131A to authorize, among other things, maintenance and wind down activities of all LIG Entities.  This GL has a shorter duration as it expires on January 17, 2026.  Please see Frequently Asked Question 1224 for additional information on authorizations regarding negotiations for the sale of LIG Entities.  

    GL 128B and GL 131A expressly authorize transactions undertaken in the ordinary course of business, provided that the transactions do not involve any blocked persons other than the LIG Entities described in GL 128B and GL 131A.  Transactions undertaken in the ordinary course of business may involve (but are not limited to):  supply of motor fuel and lubricants; lease payments; insurance payments; property maintenance and environmental services; employee payroll, benefits, severance, and reimbursements; information technology services; payments to government authorities; legal services and proceedings; payments to suppliers, landlords, lenders, and partners; the preservation and upkeep of pre-existing tangible property; and activities associated with maintaining pre-existing capital investments.  Also, both GL 128B and GL 131A authorize transactions ordinarily incident and necessary to performing pre-existing agreements and conducting intracompany transfers, provided that such transactions are consistent with previously established practices and support pre-existing projects or operations, consistent with the terms of the respective authorizations.  

    Both GL 128B and GL 131A also authorize financial institutions, payment processors, and other entities to use, debit, and credit the accounts of the relevant LIG Entities to effectuate the respective authorizations, but both GLs are also expressly limited by the condition that no funds may be transferred to a person or account in the Russian Federation.

    Non-U.S. persons generally do not risk exposure to U.S. sanctions under E.O. 14024 for engaging in transactions with blocked persons that are generally authorized for U.S. persons, including for those authorized by GL 128B and GL 131A.  Similarly, non-U.S. persons may rely upon GL 128B and GL 131A regardless of whether a foreign financial institution maintains blocked accounts, provided the non-U.S. person’s activities are consistent with the terms of GL 128B and GL 131A, including the requirement that no payments may be transferred to any person or account located in the Russian Federation. 

    Date Updated: December 18, 2025
     

    Date Released

    December 4, 2025

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  • December 17, 2025: OFAC Updates Two Russia-related General Licenses, and related FAQs

    From the OFAC Notice yesterday:

    The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Russia-related General License 55E, “Authorizing Certain Services Related to Sakhalin-2;” and Russia-related General License 115C, “Authorizing Certain Transactions Related to Civil Nuclear Energy.”

    Additionally, OFAC is amending eight Russia-related Frequently Asked Questions: FAQs 967, 978, 999, 1011, 1117, 1182, 1203, and 1216.

    Here are the two updated GLs:

    russia_gl55eDownload

    and:

    russia_gl115cDownload

    Here’s a link to a page with all the updated FAQs (in reverse numerical order, for some reason).

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  • December 17, 2025: OFSI updates two General Licences and adds a FAQ

    OFSI General Licences INT/2025/7628424 and INT/2025/7323088 amended. FAQ 175 added.

    On 17 December 2025, OFSI General Licences INT/2025/7628424 and INT/2025/7323088were amended.

    There has been an update to the definition of “IT Providers” and an amendment to the permissions in General Licence INT/2025/7628424.

    The definition of “Legal Services” has been updated in General Licence INT/2025/7323088. See FAQ 175 for details of this amendment.

    Any persons intending to use General Licence INT/2025/7628424 and General Licence INT/2025/7323088 should consult the copy of the Licence for full details of the permissions and usage requirements.

    General Licence INT/2025/7628424:

    INT-2025-7628424Download

    General Licence INT/2025/7323088:

    20251211_INT.2025.7323088_GLDownload

    FAQ 175:

    Yes. On 17 December 2025, the Legal Services General Licence INT/2025/7323088 was amended to clarify that legal advice and/or representation in dispute resolution is included in the definition of “Legal Services”.

    This was first clarified in a version of the Legal Services General Licence issued 28 March 2025 (INT/2024/5334756). It was not captured in the subsequent issue of the expired General Licence: INT/2025/6160920 dated 28 April 2025, and although not included in the original version of the current Legal Services General Licence INT/2025/7323088 (due to expire 28 April 2026), this has now been amended.

    Added on: 17 Dec 2025

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