As part of its ongoing review of licensing policy, OFSI has updated its operational policy on licensing legal services.

OFSI’s updated guidance now states that obtaining a licence is encouraged, rather than mandated, in advance of providing substantive legal services. No payment for legal services by, or on behalf of, a designated person should be received in the absence of a licence from OFSI.

This revised approach is aligned to EU legislation which contains a licensing ground enabling OFSI to permit payment of reasonable legal fees and expenses – from frozen funds or third party funds – on behalf of a designated person.

See here.


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