OFSI authorises limited processing of 2022 blocked payments involving Russian financial institutions
The UK’s Office of Financial Sanctions Implementation (‘OFSI’) has issued a new general licence (‘GL’) permitting certain blocked payment transactions from 2022 that involve non-designated third parties and Russian financial institutions.
GL INT/2024/5394840 allows ‘Relevant Institutions’ to process these payments under specific conditions outlined in the Russia (Sanctions) (EU Exit) Regulations 2019.
This new permit applies to ‘Relevant Payments’ initiated by non-designated individuals or entities and processed by a Russian-designated institution at some point in the transaction chain.
For payments to qualify, both the sender and intended recipient must be ‘non-designated persons,’ meaning they are not subject to sanctions under the Russia Regulations.
According to OFSI, a ‘Relevant Payment’ includes funds received and blocked by a non-designated institution in the UK between 1 January and 31 December 2022.
The licence specifies several conditions for processing these payments:
● Payments may only be processed by a ‘Relevant Institution’ not designated under UK sanctions.
● The final account in the payment chain must belong to either the original sender or the intended recipient.
● Funds must not be transferred, directly or indirectly, to any designated individual or entity.
‘Relevant Institutions’ authorised to process these payments include financial entities regulated under UK financial legislation, such as clearing houses and payment service providers.
In addition, institutions are required to maintain accurate records for six years and report payment details within 14 days to HM Treasury, including ‘the amount(s) processed,’ ‘the name of the Original Sender and the Original Intended Recipient,’ and the ‘payment route used.’
This licence is effective immediately and will expire on 6 November 2025.
https://assets.publishing.service.gov.uk/media/672c8c1883959cc8c18bdbab/INT_2024_5394840_GL. pdf
