The Department of the Treasury’s Office of Foreign Assets Control (OFAC) is issuing Belarus General License 14, “Authorizing Transactions Involving Belarussian Bank of Development and Reconstruction Belinvestbank Joint Stock Company and Certain Additional Entities.”
OFAC has also determined, in consultation with the U.S. Department of State, that circumstances no longer warrant the prohibitions imposed on the Ministry of Finance of the Republic of Belarus and the Development Bank of the Republic of Belarus under Directive 1 pursuant to sections 1(a)(ii), 1(b), and 8 of E.O. 14038. Accordingly, OFAC has rescinded Directive 1 under E.O. 14038.
Pursuant to the following SDN removals, OFAC has archived Belarus General License 13 as it is no longer applicable.
To make guidance on UK sanctions regimes clearer and more accessible, we’ve published summaries of prohibitions under each regime. These new summaries will enable readers to see an overview of what sanctions apply in a regime.
Each summary gives a quick overview of the sanctions in place under the regime, covering, where applicable:
the regime’s scope
what applies to designated persons and specified ships
wider financial and trade sanctions
sanctions on goods and services
additional sanction types
Regime summaries are not comprehensive and are not a replacement for the statutory guidance or the regulations themselves.
You can open the summary and the refreshed statutory guidance for each regime directly from the Current UK sanctions regimes page using the regime’s ‘guidance’ link.
595. What does Venezuela-related General License 5V authorize?
Answer
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 5V on March 19, 2026, which further delays the effectiveness of the authorization in GL 5 until May 5, 2026. Between October 24, 2019 and May 5, 2026 (the date the authorization in General License 5V 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.
1245. What activities are authorized by Venezuela General License (GL) 52, “Authorizing Certain Transactions Involving Petróleos de Venezuela, S.A.”?
Answer
GL 52 authorizes, subject to its conditions and exclusions, transactions prohibited by Executive Orders (E.O.s) 13884 or 13850 with Petróleos de Venezuela, S.A. (PdVSA) and any entity in which PdVSA owns, directly or indirectly, a 50 percent or greater interest (collectively, “PdVSA Entities”), by established U.S. entities. Transactions authorized by GL 52 include activities related to:
the lifting, exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan oil or petroleum products of Venezuelan-origin oil and petroleum products;
the provision to Venezuela of diluent, goods, services, and technologies necessary for exploration, development, or production activities in the oil, gas, or petrochemical products sectors;
entry into new investment contracts for exploration, development, or production activities in the oil, gas, or petroleum products sectors of Venezuela;
the formation of new joint ventures or other entities in Venezuela related to such activities; and
all transactions ordinarily incident and necessary to such activities, including the performance of commercial, legal, technical, safety, and environmental due diligence and assessments related to the foregoing.
Notably, GL 52 does not authorize transactions that would otherwise be prohibited by the Venezuelan Sanctions Regulations, 31 CFR Part 591, and associated Executive Orders, including E.O. 13808 and E.O. 13835, such as:
transactions related to bonds and debt issued by PdVSA and its subsidiaries, including settlement of such bonds and debt;
transactions involving equity interest in PdVSA and its subsidiaries, including the sale, transfer, assignment, or use as collateral of equity interests in PdVSA and its subsidiaries by the Government of Venezuela;
transactions involving the transfer of equity interest in PDV Holding, CITGO Holding, or CITGO Petroleum Corp.; or
transactions involving any other individuals or entities on the Specially Designated Nationals and Blocked Persons List.
GL 52 also does not authorize:
transactions that are not on commercially reasonable terms;
payment in gold or the use of debt swaps;
payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled by or in a joint venture with such persons;
transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
the unblocking of any property blocked pursuant to the Venezuela Sanctions Regulations; or
1246. Does General License 52 authorize the sale of certain shares of CITGO that are the subject of Crystallex International Corporation v. Bolivarian Republic of Venezuela?
Answer
No. A specific license will be required before any sale is executed in the Crystallex case.
Notwithstanding the existence of any general licenses under the Venezuela Sanctions Regulations (VSR), a specific license from OFAC is required for the entry into a settlement agreement, or for the enforcement of any lien, judgment, or other order through execution, garnishment, or other judicial process purporting to transfer or otherwise alter or affect property or interests in property blocked pursuant to the VSR.
And the two updated Frequently Asked Questions (FAQs) – 1226:
1226. Does “Venezuelan-origin oil” as referenced in Venezuela General License (GL) 46B, “Authorizing Certain Activities Involving Venezuelan-Origin Oil or Petrochemical Products,” include petroleum products?
Answer
Yes. Consistent with the term “Venezuelan oil” as defined in section 5(a) of Executive Order 14245, “Imposing Tariffs on Countries Importing Venezuelan Oil,” the term “Venezuelan-origin oil” means crude oil or petroleum products extracted, refined, or exported from Venezuela, regardless of the nationality of the entity involved in the production or sale of such crude oil or petroleum products.
As defined by the U.S. Energy Information Administration (EIA), petroleum products include unfinished oils, liquefied petroleum gases, pentanes plus, aviation gasoline, motor gasoline, naphtha-type jet fuel, kerosene-type jet fuel, kerosene, distillate fuel oil, residual fuel oil, petrochemical feedstocks, special naphthas, lubricants, waxes, petroleum coke, asphalt, road oil, still gas, and miscellaneous products obtained from the processing of crude oil (including lease condensate), natural gas, and other hydrocarbon compounds. In keeping with the EIA’s standard definition, petroleum products do not include natural gas, liquefied natural gas, biofuels, methanol, and other non-petroleum fuels.
Accordingly, crude oil blends such as Merey 16 or bitumen blends, as well as petroleum products or byproducts, including gasoline, asphalt, flexicoke, and petroleum coke, are considered “Venezuelan-origin oil” for the purposes of GL 46B.
Additionally, on March 13, 2026, OFAC expanded the scope of GL 46B‘s authorizations to include the purchase of Venezuelan-origin petrochemical products, including fertilizer and certain precursor chemicals identified in the Annex of the GL.
GL 46B authorizes activities that are ordinarily incident and necessary to the lifting (which refers to the physical loading and removal of oil from a terminal, storage facility, or production site for delivery to a buyer), exportation, reexportation, sale, resale, supply, storage, marketing, purchase, delivery, or transportation of Venezuelan-origin oil and petrochemical products by an established U.S. entity, which may include:
engaging in commercial, legal, and technical discussions necessary to scope purchases of Venezuelan-origin oil, including with third-party legal, commercial, or due diligence consultants;
conducting safety, environmental, and other relevant inspections, including site surveys;
arranging logistics, security services, delivery points, and shipping preparation, including obtaining marine insurance and engaging with relevant port or maritime authorities of the Government of Venezuela (GOV) or their personnel;
conducting certain downstream activities, including the refining and resale of Venezuelan-origin oil;
coordinating payment structures, including payments in the form of swaps of oil, diluents, or refined petroleum products, among others;
making required repairs and maintenance to pipeline, storage, or port infrastructure necessary to effectuate the loading of vessels; or
transactions that are not on commercially reasonable terms;
payment in gold or the use of debt swaps;
payments denominated in digital currency, digital coin, or digital tokens issued by, for, or on behalf of the Government of Venezuela, including the petro;
any transaction involving a person located in the Russian Federation, the Islamic Republic of Iran, the Democratic People’s Republic of Korea, the Republic of Cuba, or any entity that is owned or controlled by or in a joint venture with such persons;
transactions involving an entity located in or organized under the laws of Venezuela or the United States that is owned or controlled, directly or indirectly, by or in a joint venture with a person located in or organized under the laws of the People’s Republic of China;
the unblocking of any property blocked pursuant to the Venezuela Sanctions Regulations; or
any transaction involving a blocked vessel.
For information on how an entity that is not an “established U.S. entities” (including non-U.S. entities) can be involved in transactions authorized by GL 46B, see FAQ 1230.
OFSI has today published a blogpost, Reasonableness in licensing – updated approach. It provides more clarity on the evidence we require to support licence applications under the legal services and routine holding and maintenance licensing grounds, helping applicants to submit complete, well‑evidenced applications. The blogpost should be read alongside OFSI’s earlier blogpost, Reasonableness in licensing.
The updated guidance:
Reasonableness in licensing – updated approach
In June 2021, OFSI published a blogpost, “Reasonableness in licensing”, which set out how we assess “reasonableness” when considering licence applications under UK financial sanctions regimes.
This blogpost, “Reasonableness in licensing – updated approach”, updates that guidance and applies across all UK financial sanctions regimes.
OFSI regularly receives applications under the legal fees licensing ground which relate to legal services provided on ongoing and complex matters. Some of these applications request permission for payment of fees in the millions of pounds. It is for the applicant to demonstrate to OFSI that the legal fees and expenses they are requesting payment for are reasonable.
To support OFSI’s assessment of reasonableness in these cases, OFSI will now require an independent Costs Draftsperson’s Report (CDPR) to be submitted as part of the licence application in certain circumstances.
Applicants may also choose to provide a CDPR proactively even where the relevant threshold has not been met but there are other factors which increase the complexity of the application. This may assist OFSI’s assessment of reasonableness.
When a CDPR is required
OFSI will require an independent CDPR in the following cases:
Law firms – where within any six-month period:
total legal fees and Counsel fees (where instructed via solicitors), including expenses, to be licensed exceed £2,000,000.00 (inclusive of VAT)
Counsel (instructed directly) – where within any six-month period:
Counsel related costs, including disbursements, to be licensed exceed £1,000,000.00 (inclusive of VAT).
How the thresholds apply
These thresholds:
apply per UK law firm or per Counsel,
are assessed in relation to each designated person, and
are cumulative across all specific licences and applications in relation to that designated person from the law firm or Counsel.
Applications covering periods longer than six months
Where a single licence application covers a period longer than six months, OFSI will apply the relevant threshold pro rata to reflect the length of the period covered.
For example, an application covering 18 months of legal services would have threshold caps of:
£6,000,000 (inclusive of VAT) for a UK law firm (i.e., £2,000,000 per six-month period); and
£3,000,000 (inclusive of VAT) for Counsel (instructed directly) (i.e., £1,000,000 per six-month period).
What to include in your application
When submitting an application, please indicate clearly whether the criteria above apply. For example, you may wish to include a statement such as: “The legal costs exceed £2 million (including VAT) and a CDPR is attached.”
Anticipated (future) costs
OFSI recognises that applicants may seek licences for work already done and also work anticipated in the future. Where legal work is anticipated but not yet incurred, OFSI will accept a CDPR that assesses anticipated costs.
For long-running legal matters, where it is not feasible to obtain a CDPR covering anticipated costs, applicants are encouraged to consider applying for licences on a quarterly basis, with an enclosed CDPR covering costs incurred during the relevant period.
OFSI will seek to help applicants understand the licencing process, including by directing them to relevant guidance.
Disbursements
Where the threshold requiring a CDPR has been met, OFSI may, on a case-by-case basis and in extenuating circumstances, agree to assess disbursements (excluding Counsel fees or other legal services) without the provision of a CDPR separately in advance of the assessment of the wider legal fees element of the application. Examples include where a disbursement must be paid on a time‑critical basis to avoid prejudice to legal proceedings, and the applicant can provide clear evidence for that disbursement even though the CDPR for the wider legal fees is not yet available.
This is at OFSI’s discretion, and applicants should provide clear supporting evidence for the disbursements in question.
Independence and qualification of the Costs Lawyer
CDPRs must be produced by independent practising Costs Lawyers who:
are regulated by, and hold a current practising certificate issued by, the Costs Lawyer Standards Board (CLSB);
comply with the CLSB’s Code of Conduct; and
are not part of the legal team undertaking the work covered by the OFSI licence application.
How OFSI uses the CDPR and assesses reasonableness
A CDPR is one part of the evidential package that OFSI will consider when assessing whether legal fees and expenses are reasonable. We will look at the CDPR alongside other material you provide.
However, even where a CDPR concludes that costs are reasonable, OFSI may still determine that reasonableness has not been fully demonstrated; license a lower amount than requested; or decline to license certain costs altogether.
The costs of obtaining a CDPR may be licensed under the legal services licensing ground, subject to the normal reasonableness test. These costs can be included within the main legal services application or sought via a separate licence application.
You may apply for CDPR costs before you submit the primary application, at the same time as an application, or as a separate application after the primary application has been considered. In all cases, OFSI will assess the CDPR costs in the same way as any other legal fees and reasonableness must be demonstrated.
Legal services: Administrative and other additional fees
OFSI sometimes receives legal services licence applications that include an additional administration or similar fee applied as a percentage uplift to the total of fee earners’ charges.
To assess the reasonableness of any such fee, OFSI requires applicants to provide:
a clear, itemised breakdown of what the administration (or similar) charge covers; and
supporting evidence demonstrating the basis for, and level of, those costs.
Where this information is not provided, OFSI will not be able to assess the fee as reasonable and may refuse to license it. Applicants should therefore provide this information at the outset, as it is likely to enable a quicker assessment.
Maintenance of frozen funds and economic resources licensing ground: independent expert reports
For applications under the maintenance of frozen funds and economic resources licensing ground, applicants are encouraged to submit an independent expert report where the requested payments are high value, novel, or complex. For example, this could be payments related to a niche asset (such as a superyacht or racing car) for which expertise is required to determine the maintenance required; or for extraordinary payments which are not routinely required (for example, significant construction works to prevent a building falling into disrepair).
Where an expert report is not provided, OFSI may on a case-by-case basis and at OFSI’s discretion, request one where it is needed to support our assessment of the necessity and reasonableness of the proposed costs.
Type and qualification of the independent expert
The independent expert should have demonstrable and relevant expertise in the area to which the costs relate. This expertise may be demonstrated through relevant experience and/or appropriate professional accreditation.
Examples include, but are not limited to:
Maritime assets – a marine surveyor or naval architect accredited by a recognised professional body.
Aviation – an aircraft engineer or aviation asset manager with appropriate professional registration.
Technical infrastructure / industrial assets – an engineer with chartered status (or equivalent) in the relevant discipline and experience of maintaining comparable assets.
The expert should:
be independent of the applicant and any service provider benefiting from the payments;
have no financial interest in the proposed works or services, beyond standard professional fees for preparing the report; and
provide a signed report, prepared and presented in line with the relevant professional/industry standards, setting out the basis for their opinion on the proposed costs and their necessity.
How OFSI uses the report and assesses reasonableness
As with CDPRs, OFSI will treat any independent expert report as part of the overall evidential package. Even if the report supports the proposed costs, OFSI may conclude that costs are not fully justified and license a reduced amount or decline certain costs.
Cost of obtaining independent expert reports
As with CDPR fees, the costs of obtaining an independent expert report may be licensed under the relevant licensing ground, subject to the normal reasonableness test. Applicants may include these costs within the main application or request them via a separate licence application.
OFSI will assess the reasonableness of independent expert fees case-by-case, taking account of the scope, complexity, location, and urgency of the works.
To assist OFSI’s assessment, applicants should provide (as applicable):
A clear scope of services: what the expert will do, deliverables, and the time period covered.
How the fee is calculated: whether a fixed fee (and what it covers), or hourly rates and estimated hours (including any fee cap).
Evidence of market reasonableness: multiple quotes/tenders, or an explanation of why a single provider was selected.
Evidence to demonstrate reasonableness
OFSI will continue to assess reasonableness in line with our existing guidance and policy (see Reasonableness in Licensing).
Evidence submitted to demonstrate reasonableness should be recent and as a general rule, OFSI considers evidence dated within the past 6 months to be appropriate (in relation to the application).
Where evidence is older than 6 months, applicants must provide a clear explanation of:
why more recent evidence could not be obtained; and
why the older evidence remains a reliable basis for assessing reasonableness (for example, due to the nature of the market or stability of pricing).
Further information
These updates are intended to enhance transparency around OFSI’s assessment of reasonableness, and to help applicants prepare complete and well evidenced applications. This should support more efficient processing of applications and clearer outcomes.
the relevant regime-specific and thematic guidance on GOV.UK; and
the terms of any applicable General Licences.
If you are unsure how these updates affect your application, you can contact OFSI using the details provided on GOV.UK.
and the original post, from June 2021:
Reasonableness in licensing
If you are applying for a licence from OFSI to release otherwise frozen funds for legal fees or the maintenance of frozen funds or economic resources, you will likely come across the term “reasonableness”.
When issuing a licence to enable the payment of professional fees and expenses for the provision of legal services, OFSI is legally obliged to ensure that those fees and expenses are “reasonable”.
OFSI’s Introduction to licensing blog, which was published in April 2021, set out the key changes to licensing under the Sanctions and Anti Money Laundering Act (the Sanctions Act) that came into effect from 23.00 on 31 December 2020. The following changes to reasonableness now apply:
Under the legal fees licensing ground, reasonableness now also applies to expenses
A reasonableness test has been applied to the maintenance of frozen funds and economic resources licensing ground.
OFSI receives many applications where applicants have not provided sufficient evidence of reasonableness or with no evidence at all. This could be because the applicant may not understand the full policy intention behind the regulations that need to be considered in parallel, or the justification submitted may be one-sided in the applicant’s favour. However, OFSI requires a significant level of evidence when scrutinising the reasonableness threshold. This is because the Sanctions Act which gives us the power to issue these licences, also stipulates that legal fees and maintenance of frozen funds should be ‘reasonable’. When we don’t receive the level of detail that we need, we will need to engage with the applicant for these further details. This can invariably cause delays in processing such licence applications and, in some cases, may result in the refusal of the licence application if further information is never provided. OFSI does not want to cause delays to the consideration and issuance of any of our licences, so this blog is aimed at setting out what information we need to consider when identifying if an application is “reasonable”.
Financial sanctions are a foreign policy tool. In the UK they are implemented through UK legislation (which sometimes applies restrictions imposed through the UN) in order to achieve a specific foreign policy or national security objective. Financial sanctions are generally imposed to:
coerce a regime or individual to change their behaviour;
constrain a target by denying access to key resources to continue their offending behaviour;
signal disapproval; and
protect the value of assets that have been misappropriated from a country until these assets can be repatriated.
As the competent authority for the implementation of financial sanctions in the UK, OFSI has to ensure that any permitted release or use of frozen funds maintains the integrity of the financial sanctions regime, supports the foreign policy ambition and that the decision to release remains in line with its legal duty under UK law. The term ‘reasonable’ is written in to the Sanctions Act which means there is a legal requirement both for OFSI to assess this and for applicants to provide evidence of why a payment is reasonable.
If you are in possession of an OFSI licence that permitted the use of frozen funds for the payment of legal fees/maintenance under the previous EU regulations, you may need to provide a new explanation for reasonableness, if that licence requires an amendment. In addition, if you were granted a licence that has now expired after only being partially used, or not used at all, any new application will need to meet the new requirements as set out under the Sanctions Act for the regime. This should include explaining and/or evidencing the reasonableness of the payments. Licence extensions under derogations that have reasonableness written into them will need to undergo ‘reasonableness’ assessments again. This can be done by providing evidence such as previous invoices against the licence to assist OFSI in its determination that the costs remain reasonable and whether all of the licence is being used in the same way that it was when the licence was initially granted.
The two licensing derogations under the Sanctions Act that include a ‘reasonableness’ test are ‘legal services’ and ‘maintenance of funds or frozen resources’. We have broken them down below and have outlined the types of questions that applicants may wish to consider when applying under these specific licensing grounds.
Legal Services
It is for the applicant to demonstrate to OFSI that the legal fees and expenses they are requesting payment for are reasonable. OFSI considers that the Solicitors’ guideline hourly rates or the sums that could be expected to be recouped if legal costs were awarded following civil court proceedings, provide a useful starting point for assessing the reasonableness of legal fees and expenses. If you seek fees of a level above those set out in the guideline, you need to demonstrate why those increased fees are reasonable in the given case. Whilst we will consider rates that vary from the guideline, it is a useful benchmark in the assessment of reasonableness.
When applying to for a legal fees and expenses licence, you should consider addressing the following in your application form:
Whether the work has already taken place or if it is anticipated work;
What the work will involve/has involved;
Which fee earner(s) will be/have been involved in the work (and their position(s)/role(s) within the firm, including relevant level of experience);
The fee earner(s)’ hourly rate;
How many hours each fee earner(s) will be estimated to spend/has already spent on each workstream;
Any supporting evidence as to why the involvement and/or the number of hours of the particular fee earner(s) is reasonable and/or proportionate to the nature and complexity of the work;
Any expenses that are expected and have been paid out; and
If any expenses are expected, why are they necessary.
If you are requesting a licence amendment to permit an increase in the hourly rate of fee earner(s) you should provide a detailed explanation. For example, this may be a breakdown and evidence of the firm’s running costs to explain the proposed increase. When OFSI reviews such amendments, it is not enough to cite for example, “an engagement letter between the DP and the law firm” which provides for an annual increase, nor that it is a “common practice amongst law firms”. As set out in OFSI’s guidance, legal services may be provided without a licence, but any payments for legal services provided, do require a licence.
In terms of legal professional privilege (LPP), OFSI expects legal professionals to carefully ascertain whether LPP applies and which information it applies to. It is not generally considered that fees notes and narratives of work (in generic terms) are privileged as they do not constitute the giving or obtaining of legal advice. OFSI may challenge a blanket assertion of LPP where it is not satisfied that such careful consideration has been made. For example, simply providing the cost of a workstream without providing a breakdown due to LPP is not satisfactory. This is because OFSI is unable to undertake a reasonableness assessment without having a breakdown of the individual legal cost for each area of work.
Maintenance of funds and frozen resources
Under the derogation of ‘Maintenance of funds and frozen resources’, licences may be issued for a number of purposes. These can range from the supply of Covid-related personal protective equipment, to property maintenance. When a licence application or amendment request is submitted under this derogation, sufficient evidence will need to be included for OFSI to make a decision. When applying, you should consider the following in your application form:
Provide evidence when submitting your licence application. Appropriate evidence will vary based on what you are applying for.
Explain why the proposed activity is necessary. You may wish to explain what the outcome would be should you not receive a licence.
Where appropriate, consider obtaining quotes from more than one supplier to ensure that the fees can be demonstrated as reasonable and that you are receiving value for money.
If a quote is unable to be obtained, provide an evidence-based estimate. If you are a property management company looking to obtain a licence for a commercial building, you may wish to use quotes from similar-sized commercial buildings as evidence for reasonableness.
Provide a breakdown of the proposed payment/work. If you are requesting a licence to pay £100,000 for a change of windows, provide a breakdown of the payment – this could include the exact number of windows you are looking to change, cost of personnel and/or material etc.
If you are applying for a licence extension, you will be required to undergo the reasonableness assessment again. This may include reviewing your licence to ensure it is being used.
For any applicant that is submitting a licence application under a derogation that has ‘reasonableness’ written in to the regulations, you should use your own best judgement and not assume OFSI understands the process and practice of the profession when providing your response. We understand that reasonableness may have different meanings in different contexts and applicants should note that just because a payment has been licensed on a previous case, does not automatically mean that it will necessarily be licensed again. This is why OFSI considers each application on a case by case basis and the above pointers serve as a guideline of best practice when engaging with us.
For further information on licensing and financial sanctions implementation, please refer to OFSI’s general guidance.
To make guidance on UK sanctions regimes clearer and easier to navigate, we’ve introduced a series of improvements to structure and wording of the statutory guidance.
You do not need to take any action. These changes make the sanctions guidance easier to read and use, and do not reflect changes to the meaning of the text or scope of the regulations.
Summary of changes to statutory guidance, by section:
Prohibitions and requirements: Minor changes to text throughout. Wording under ‘Director disqualification’ and ‘Information and record keeping’ is updated, and an introductory section added.
Enforcement: Deletion of content that duplicates departmental enforcement guidance. This section will link out to departmental guides.
Licences and exceptions:
3.1 Exceptions: Added introductory definition of exceptions. Each exception now has a header, and links to additional departmental guidance where helpful. New ‘lookup’ guide for exceptions to the Belarus trade and transport sanctions.
Older versions of statutory guidance and other GOV.UK pages can be accessed for reference via the National Archives Web Archive.
This improvement to sanctions guidance delivers on recommendation ii of the May 2025 cross-Whitehall review of sanctions.
The UK Sanctions List from FCDO lists which people, entities and ships are designated or specified under the Sanctions and Anti-Money Laundering Act 2018, and why.
Issued along with the enforcement strategy document today, a slightly different set of government agencies (NCA, FCDO, HMRC, HM Treasury, Department for Business & Trade and the Department for Transport) issued the results of their overall review of UK sanctions – here’s a summary:
The “Cross-Government Review of Sanctions Implementation and Enforcement,” published in May 2025, served as the foundational “blueprint” for the UK’s modern sanctions strategy. While the March 2026 document (summarized previously) focuses on how the government will enforce the rules, this May 2025 Review explains the why and the what—detailing the specific structural changes and systemic upgrades being implemented.
For those with a basic grounding in the subject, this review marks the transition from the UK simply having sanctions to the UK having a professionalized, high-tech enforcement machine.
1. The Core Objective: “From Policy to Impact”
The review acknowledges that after 2022, the UK’s sanctions list grew exponentially. The primary goal moved from “designing” sanctions to “operationalizing” them. The government identified three pillars for improvement:
Compliance: Making it easier for legitimate businesses to follow the rules.
Deterrence: Making it riskier and more expensive to break the rules.
Toolkit: Ensuring agencies have the legal powers and tech to catch evaders.
2. Major Structural Reforms
This document is where several major initiatives were first formalized:
The Launch of OTSI: It confirmed the standing up of the Office of Trade Sanctions Implementation (OTSI) to mirror OFSI but for trade in services and global movements of goods.
The “Single Sanctions List”: Recognizing that businesses were frustrated by checking multiple government lists, the review committed to consolidating the FCDO’s “UK Sanctions List” and HM Treasury’s “Consolidated List” into a single, user-friendly portal.
Centralized Reporting: It explored the “single reporting point” concept—moving away from a confusing system where businesses didn’t know whether to report to HMRC, OFSI, or the NCA.
3. Fixing “Pain Points” for Industry
The review explicitly addressed common complaints from the private sector:
Ownership and Control: It promised clearer guidance on the “50% rule” and how to handle complex trusts or corporate structures that hide a sanctioned person’s influence.
“Teachable Moments”: The government committed to publishing more “case studies” of past breaches. Instead of just issuing a fine in private, they decided to publicize the specific mistakes companies made to help others avoid the same traps.
Guidance Overhaul: It flagged that existing guidance was often too “legalistic” and committed to rewriting it for non-lawyers.
4. Expansion of Penalties (The Origins)
The review recommended the specific enforcement tools that were later seen in the 2026 strategy:
The “Fast-Track” System: It proposed the creation of small, fixed penalties for minor technical errors (like filing a report late) to keep the system moving.
Early Settlement Discounts: It introduced the concept of the 20% to 40% discounts for companies that cooperate early, modeled after the “compound settlements” already used by HMRC.
5. Whistleblowers and Intelligence
A significant takeaway from this review was the focus on Intelligence-Led Enforcement.
Whistleblower Protections: The review highlighted the need to better protect employees who “blow the whistle” on sanctions evasion within their own firms.
The “Shadow Fleet”: It identified a specific need to tackle the “Russian Shadow Fleet” (vessels used to bypass the Oil Price Cap) by better-integrating maritime data from the Joint Maritime Security Centre (JMSC).
Summary for Businesses
The May 2025 Review was essentially the government saying: “We heard your complaints that the system is confusing, and we are fixing it—but in exchange, we are going to be much more aggressive about finding and punishing those who ignore the rules.” It represents the birth of a more integrated, data-driven approach to UK sanctions that treats trade and financial breaches as two sides of the same coin.
Today, the Department of State announces the designation of the Sudanese Muslim Brotherhood as a Specially Designated Global Terrorist and the intent to designate the group as a Foreign Terrorist Organization.
The Sudanese Muslim Brotherhood (SMB), composed of the Sudanese Islamic Movement and its armed wing – the al-Baraa Bin Malik Brigade (BBMB), uses unrestrained violence against civilians to undermine efforts to resolve the conflict in Sudan and advance its violent Islamist ideology.
The SMB has contributed upwards of 20,000 fighters to the war in Sudan, many receiving training and other support from Iran’s Islamic Revolutionary Guard Corps.
SMB’s BBMB fighters have conducted mass executions of civilians in areas they captured, and repeatedly and summarily executed civilians based on race, ethnicity, or perceived affiliation with opposition groups.
The Treasury Department designated BBMB in September 2025 pursuant to Executive Order 14098, “Imposing Sanctions on Certain Persons Destabilizing Sudan and Undermining the Goal of a Democratic Transition” for its role in Sudan’s brutal war.
Terrorist designations expose and isolate entities and individuals, denying them access to the U.S. financial system and the resources they need to carry out attacks.
All property and interests in property of the Sudanese Muslim Brotherhood that are in the United States or that are in possession or control of a U.S. person are blocked. U.S. persons are generally prohibited from conducting business with sanctioned persons.
Persons that engage in certain transactions or activities with the Sudanese Muslim Brotherhood may expose themselves to sanctions risk. Notably, engaging in certain transactions with them entails risk of secondary sanctions pursuant to counterterrorism authorities.
Today’s actions are taken pursuant to section 219 of the Immigration and Nationality Act and Executive Order 13224. Foreign Terrorist Organization designations go into effect upon publication in the Federal Register.
Petitioners requesting removal of those designated today from the Specially Designated Nationals and Blocked Persons List should refer to the Department of State’s Delisting Guidance page.
On Thursday, OFAC issued Russia-releated General License 133 (Authorizing the Delivery and Sale of Crude Oil and Petroleum Products of Russian Federation Origin Loaded on Vessels as of March 5, 2026 to India):
1238. Would OFAC approve the resale of Venezuelan origin oil to Cuba?
Answer
In accordance with the United States’ support and solidarity for the Cuban people, OFAC would implement a favorable licensing policy toward specific license applications seeking authorization for the resale of Venezuelan-origin oil for use in Cuba. To qualify for this favorable licensing policy, the requested transactions would need to be consistent with the terms and conditions of Venezuela General License (GL) 46A, though applicants need not necessarily have an established U.S. entity and the limitations in GL 46A with respect to Cuba would not apply. This favorable licensing policy is directed towards transactions that support the Cuban people, including the Cuban private sector (e.g., exports for commercial and humanitarian use in Cuba). Consistent with applicable U.S. law and policy, transactions involving, or for the benefit, of any persons or entities associated with the Cuban military, intelligence services, or other government institutions, including entities listed on the U.S. State Department’s Cuba Restricted List, see 31 C.F.R. 515.209, as well as any Cuban-owned financial institutions, would not be covered by this favorable licensing policy (collectively, the “excluded parties”).
Parties seeking a license under this policy must implement measures to ensure that no subsequent transactions related to the Venezuelan-origin oil involve or benefit, either directly or indirectly, the excluded parties. These measures should include provisions in sale or resale agreements prohibiting any direct or indirect participation by the excluded parties in any present or future transaction related to the Venezuelan-origin oil, as well as requirements that any present or future financial transactions involving the sale or resale of the Venezuelan-origin oil are routed through a financial institution based in the United States, or otherwise do not involve transactions routed through financial institutions associated with, or controlled by, the excluded parties.
As a reminder, the U.S. Department of Commerce primarily regulates the export or reexport of U.S.-origin oil to Cuba, as well as all other items subject to the Export Administration Regulations (EAR, 15 C.F.R. parts 730-774). Treasury’s Cuban Assets Control Regulations generally authorize U.S. persons to engage in transactions ordinarily incident to the export of oil from the United States to Cuba, or the reexport of U.S.-origin oil from a third country to Cuba, where that export or reexport has been authorized by the Commerce Department. See 31 C.F.R. 515.533(a). This authorization applies to transactions covered by applicable Commerce Department license exceptions, including License Exception Support for the Cuban People (SCP), 15 CFR § 740.21, which authorizes exports and reexports of gas and other petroleum products to improve living conditions and support independent economic activity. In other words, U.S.-origin oil exports, as well as other gas and petroleum products covered by License Exception SCP, do not require separate OFAC authorizations. Exporters and reexporters are responsible for reviewing current Commerce Department guidance, see here, and ensuring that any transaction undertaken pursuant to License Exception SCP or any other license exception meet all applicable terms and conditions.
See FAQ 1226 for the definition of “Venezuelan-origin oil,” which includes petroleum products.
