The new license was issued due to the expiration of the previous license, but certain modifications were added:

• The threshold limiting the amount payable for legal fees has been increased from £500,000 to £2 million;

• The concept of the “law firm” has been expanded to include, among others, employees providing legal services to designated persons;

• the threshold for the amount of expenses associated with the provision of legal services under the license has been increased to £200,000 or 10% of the amount payable for legal fees, whichever is lower;

• it is now allowed to make payments to bank accounts outside the UK, specifically, to separate accounts of branches of the UK law firms;

• the reporting period for sending lawyers’ reports to OFSI has been increased from 7 to 14 days after receiving payment.

The license is in effect until April 28, 2025.

To reflect these changes, OFSI has also updated Frequently Asked Questions (FAQs) on financial sanctions 49-51, 55, 61-66, 72-73, 76, and 84. The FAQs further clarify, among other things, that the fee caps apply to all in-house lawyers employed by designated companies as if they were, together, a law firm. The caps also apply to directly instructed counsel (FAQ 62).