UK GVT Counter-Terrorism Licensing


On Jan. 11, UK GVT issued new general licences and legal aid rules.


  • UK GVT provided amendments to the counter-terrorism licensing policy following the UK's exit from the EU, including amendments made by the Treasury to legal aid rules.
  • Overview
  • Licences authorize activities or transactions otherwise prohibited by sanctions law.
  • In addition to issuing licences relating to a specific person, the Treasury may also issue general licences, authorizing otherwise prohibited activity by a category of persons.
  • The objective of the licensing system for terrorism designations is to strike a balance between limiting risk of diversion of funds to terrorism and respecting human rights.
  • The Treasury only grants licences where there is a legitimate need for such activities or transactions to proceed and can do so without giving rise to a risk of terrorist finance.
  • This helps to ensure the sanctions regime remains effective, fair and proportionate.
  • General Licences And Legal Aid
  • General licences can be used without making an application to UK OFSI, although they do still carry a mandatory reporting requirement to UK OFSI if they are actually used.
  • This licence permits the Legal Aid Agency (LAA) to make payments to solicitors representing a designated person where the LAA has assessed that the individual is eligible for legal aid, and for those funds to be applied by solicitors to meet legal costs.
  • This only applies for costs incurred in the course of advising and representing the designated person and no monies may be made available to any designated person.
  • Applicants should note that Treasury licences do not determine entitlement to receive specific benefits and the general licence for legal aid does not determine entitlement.
  • Entitlement to legal aid remains a matter for LAA, and authorities in devolved nations.
  • The licence simply means that where a designated person is entitled to legal aid, the provision of those funds to pay legal costs will not be a breach of sanctions legislation.
  • 2021 Amendments
  • Existing licences issued by UK OFSI for counter-terrorism designations will generally continue to remain valid until they expire or are revoked.
  • However, on Jan. 11, 2021, UK Treasury revoked 3 general licences which all related to the provision of insurance and in respect of the payment of legal fees by third parties.
  • These may no longer be used, and future applications relating to insurance policies and payment of legal fees by third parties, will be assessed on a case-by-case basis.
  • Where a payment is no longer covered by a general licence, as a result of these changes, those affected should contact the Treasury to apply for an individual licence.
  • The Treasury also revoked and replaced the general licence that related to legal aid.

Regulators UK GVT; UK OFSI; UK Treasury
Entity Types CNSM; Corp
Reference PS, PR 1/11/2021
Functions Compliance; Financial; Legal; Operations; Registration; Reporting; Risk
Countries United Kingdom
Products Corporate; Payments
Regions EMEA
Rule Type Guidance
Rule Date 1/11/2021
Effective Date 1/11/2021
Rule Id 95237
Linked to N/A
Reg. Last Update 1/11/2021
Report Section UK

Last substantive update on 01/12/2021