New license for the Provision of Legal Services in the UK
On October 28, the UK Office of Financial Sanctions Implementation (OFSI) issued a new general license for the provision of legal services to designated persons of the Russian Federation and the Republic of Belarus.

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).

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