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World ECR | OFSI Authorizes Limited Processing 2022

The UK Office for Financial Sanctions Implementation (OFSI) has issued a new General License (GL) to allow certain blocked payment transactions involving non-designated third parties and Russian financial institutions from 2022.

GL INT/2024/5394840 allows “relevant authorities” to process these payments under certain conditions set out in the Russia (Sanctions) (EU Withdrawal) Regulations 2019.

This new license applies to “relevant payments” initiated by non-designated individuals or entities and processed by a Russian designated authority at some point in the transaction chain.

In order for a payment to qualify, both the sender and intended recipient must be “non-designated persons,” meaning they are not subject to Russian regulations.

OFSI said “relevant payments” include funds received and frozen by non-specified institutions in the UK between January 1 and December 31, 2022.

The license stipulates several conditions for processing these payments:

● Payments can only be processed by “relevant authorities” designated not subject to UK sanctions.

● The final account in the payment chain must belong to the original sender or intended recipient.

● Funds may not be transferred, directly or indirectly, to any designated person or entity.

“Relevant authorities” authorized to process these payments include financial entities regulated by UK financial legislation, such as clearing houses and payment service providers.

In addition, institutions must keep accurate records for six years and report payment details to HM Treasury within 14 days, including the “amount processed,” the “names of the original sender and original intended recipient,” and the “payment route used.”

The license is effective immediately and will expire on November 6, 2025.

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