OFSI Updates: Expiry of Russian Oil Companies Wind Down General Licence INT/2025/8202932 – Need for Specific Licence in Future

The OFSI has issued an update to its UK Financial Sanctions FAQs (5 February), highlighting the expiry of General Licence INT/2025/8202932 on 31 January 2026. This latest addition to the list of expired GLs is a reminder to firms and clients to ensure their sanctions processes are up to date.

The expired GL, granted under Regulation 64 of the Russia (Sanctions) (EU Exit) Regulations 2019, previously allowed wind down transactions with certain Russian oil companies. As it is no longer valid, parties must not rely on it. No further activities, even those which close out positions with the associated designated parties are permitted. Affected parties should therefore assess the need to obtain permission from OFSI by acquiring a valid, specific licence.

Summary
The expiry of the Russian Oil Companies Wind Down General Licence and the latest OFSI FAQs updates reflect the dynamic, and stringent, nature of the UK sanctions landscape.

This is also a reminder that parties must continually assess all ongoing relationships with designated Russian oil companies.

Against this backdrop, please keep an eye out for our next post in which we discuss the Legal Services General Licence INT/2025/7323088, which is the key framework allowing UK Law Firms and Counsel to receive payment from sanctioned or designated persons for OFSI-defined “legal services” provided under any of the UK Autonomous Sanctions Regimes.

This post is written by Abdullah Iqbal AIqbal@m-f-b.co.uk and Pete Gercans PGercans@m-f-b.co.uk