News

New framework for prioritising sanctions licence applications

The Office of Financial Sanctions Implementation (OFSI) has published guidance on how it prioritises licence applications. OFSI receives a wide variety of licence applications each year, ranging from urgent humanitarian requests to complex commercial transactions. It has published its prioritisation framework to help applicants understand the process.

As a solicitor or compliance officer, this guidance will help you to:

  • judge timelines for action
  • explain and manage client expectations
  • avoid unnecessary resubmissions.

Each licence application is assessed against seven criteria. These criteria help caseworkers understand urgency, risk, stakeholder impact and possible harm caused by delay.

  • Nature of the licensing purpose.
  • Materiality to the applicant or affected parties.
  • Timing considerations.
  • UK economic impact.
  • Administrative impact on OFSI.
  • Reputational or strategic impact.
  • Complexity of the application.

Generally, applications on humanitarian grounds, where a risk to life is demonstrated, or which involve deadlines such as court dates will be treated as highest priority.