General Licence INT/2026/9512597 UK Autonomous Sanctions Regulations Legal Services

GENERAL LICENCE - Legal Services INT/2026/9512597

1. This licence is granted under the UK Autonomous Sanctions Regulations listed in Annex 1 of
   this licence.

2. Any act which would otherwise breach the prohibitions in the UK Autonomous Sanctions
   Regulations, as listed in Annex 1 of this licence, is exempt from those prohibitions to the extent required to give effect to the permissions in this licence.

3. In this licence (including Parts A and B):
   "Expenses" means any fees or expenses associated with the provision of the Legal

Services including (but not limited to):

• fees for expert witnesses;
• translation fees;
• printing;
• travel expenses;
• subsistence expenses;
• courier expenses;

• legal searches;
  "Counsel" means: • court transcripts; "DP" means those individuals or entities designated (or owned or controlled "Funds" means financial assets and benefits of every kind, including (but not

• a barrister who is regulated by the Bar Standards Board or by the • administrative fees necessary to provide legal services (i.e. Home "DP Group" means a DP designated for the purposes of an asset freeze by the UK by an individual or entity designated) for the purposes of an asset freeze limited to)--
  Bar Council of Northern Ireland; or Office fees); and under the UK Autonomous Sanctions Regulations, excluding those "Economic means assets of every kind, whether tangible or intangible, movable or by the UK under the UK Autonomous Sanctions Regulations, excluding (a) cash, cheques, claims on money, drafts, money orders and

designated for the purpose of compliance with United Nations those designated for the purpose of compliance with United Nations Resources" immovable, which are not funds but can be used to obtain funds, goods • an advocate who is regulated by the Faculty of Advocates • bank transaction fees, other payment instruments;

and who is providing advice in relation to the Legal Services. obligations. obligations, together with any entities owned or controlled by that DP. or services. but excluding Counsel's fees. (b) deposits, balances on accounts, debts and debt obligations;

"Relevant means a Person that has permission under Part 4A of the Financial Institution" Services and Markets Act 2000 (permission to carry on regulated

activity); (c) publicly and privately traded securities and debt instruments, a Person that is authorised or registered under Part 2 of the including stocks and shares, certificates representing securities, Payment Services Regulations (SI 2017/752); bonds, notes, warrants, debentures and derivative products;

"Legal Adviser" means a person who is professionally qualified or is undertaking a a Person that is authorised or registered under Part 2 of the (d) interest, dividends and other income on or value accruing

professional legal qualification and is providing legal advice in relation to Electronic Money Regulations (SI 2011/99); from or generated by assets; the Legal Services to a DP, including (but not limited to): "Law Firm" means a Person providing legal advice in relation to the Legal Services to "Non-UK Bank means an account at a bank or similar institution, which is a Person a Person that is a "recognised clearing house", "third country (e) credit, rights of set-off, guarantees, performance bonds and

• solicitors; Account" subject to supervision by a public authority, in: central counterparty", "recognised CSD" or "third country CSD" a DP. Where one or more Legal Advisers and/or Counsel are employees other financial commitments;
• CILEX practitioners or chartered legal executives; of a DP, and provide Legal Services to that DP, they shall collectively be "Legal means legal services provided to a DP, including legal advice and/or a) Canada; for the purposes of s.285 of the Financial Services and Markets (f) letters of credit, bills of lading and bills of sale;
• trainee solicitors; deemed to be one "Law Firm", instructed by that DP, solely for the Services" representation in dispute resolution, whether provided within the UK or b) any Member State of the European Union; Act 2000; or (g) documents providing evidence of an interest in funds or
• paralegals; and purposes of the provisions of this licence which express a financial limit another jurisdiction, in relation to any matter except a claim for c) any Member State of the European Free Trade Association; or "professional means fees charged by a Legal Adviser or a Law Firm for the provision of a Person that is an operator of a recognised payment system (or financial resources; "Person" includes a body of persons corporate or unincorporate, but does not to apply 'per Law Firm'. defamation or malicious falsehood. d) the United States. include a DP. legal fees" the Legal Services. that is a service provider in relation to recognised payment • legal executives. (h) any other instrument of export financing.

1. Subject to paragraph 6, provided that one (or both) of the sets of conditions in Part A and/or Part B of this licence are complied with in full any Person, Relevant Institution or provider of a Non-UK Bank Account may:

4.1. receive payments from or on behalf of a DP; 4.2. make payments (directly or indirectly) for or on behalf of a DP; 4.3. make payments for the benefit of a DP; 4.4. process payments which relate to a DP; and 4.5. carry out any other act which is reasonably necessary to give effect to 4.1 - 4.4 above.

1. Subject to paragraph 6, provided that one (or both) of the sets of conditions in Part A and/or Part B of this licence are complied with in full, a DP may pay professional legal fees, Counsel's

fees, and/or Expenses to a Law Firm, a Legal Adviser, Counsel or a provider of Expenses for Legal Services which have been provided to that DP or to any other DP in the same DP Group.

1. The permissions in this licence do not authorise any act which results in Funds or Economic

Resources being made available (directly or indirectly) to any DP.

1. This licence does not permit payment directly or indirectly to or for the benefit of any person
   designated for the purpose of compliance with United Nations obligations.

2. Both Part A and Part B of this licence can be used in conjunction by a Person or DP if the
   provision of Legal Services commenced before the DP was designated and continued after designation provided that:

8.1. any professional legal fees and any Counsel's fees, paid under both Parts in relation to a

DP Group or where there is not a DP Group, the designated entity or individual, do not exceed £4,000,000 (including VAT where applicable) per Law Firm (or per Counsel, if engaged under a direct instruction) instructed in total for the duration of this licence;

8.2. the Expenses paid under both Parts in relation to a DP Group or where there is not a DP

Group, the designated entity or individual, do not exceed (in total) either: 8.2.1. 10% of the amount payable for professional legal fees and Counsel's fees; or 8.2.2. £400,000.00 whichever is lower, for all of the Expenses per Law Firm (or per Counsel, if engaged under a direct instruction) instructed for the duration of this licence;

8.3. where a Law Firm, Legal Adviser or Counsel has not received professional legal fees and/or

Counsel's fees from or on behalf of a DP under this licence, Expenses paid under both Parts in relation to a DP Group or where there is not a DP Group, the designated entity or individual do not exceed (in total) £100,000 per Law Firm (or per Counsel, if engaged under a direct instruction) instructed for the duration of this licence;

8.4. Part A is only used to pay for individual matters within the Legal Services which were

commenced before the DP was designated; and

8.5. With regard to the provision of Legal Services under Part B, the hourly rates do not exceed

those set out in paragraphs 8 and 14 of Part B.

"UK means those sanctions regulations made under the Sanctions and Anti-

Autonomous Money Laundering Act 2018 listed in Annex 1 of this licence. Sanctions systems) for the purposes of Part 5 of the Banking Act 2009. Regulations"

1. The permissions in this licence do not authorise any act which results in a breach of the UK
   Autonomous Sanctions Regulations set out in Annex 1 made under the Sanctions and Anti- Money Laundering Act 2018 save as specifically permitted under this licence or other licences granted under the UK Autonomous Sanctions Regulations listed in Annex 1.

2. Any Person, Relevant Institution or DP acting under the authority of, or otherwise using this
   licence should note that the conditions set out in Parts A and B of this licence are not capable of being interchanged: the conditions in one Part must be complied with in full for the activities to fall within the terms of this licence.

3. Information provided to HM Treasury in connection with this licence shall be disclosed to third
   parties only in compliance with the UK General Data Protection Regulation and the Data Protection Act 2018.

4. This Licence takes effect from 00:01 on 29 April 2026 to 23:59 on 28 October 2026.

5. HM Treasury may vary, revoke or suspend this licence at any time.

6. HM Treasury will publicise any variations, suspensions or revocations of this licence online at
   www.gov.uk/government/collections/ofsi-general-licences. Signed:

Office of Financial Sanctions Implementation HM Treasury 24 April 2026

PART A - LEGAL SERVICES BASED ON A PRIOR OBLIGATION CONDITIONS FOR USE OF THIS PART OF THE LICENCE- NOTE THAT ALL OF THE BELOW CONDITIONS MUST BE SATISFIED/ COMPLIED WITH.

1. A payment of: 1.1. professional legal fees; and/ or 1.2. Counsel's fees; and/ or 1.3. Expenses,

must be owed by a DP to a Law Firm, a Legal Adviser, Counsel or a provider of Expenses.

1. The payment must be in relation to Legal Services which have been provided, or which are
   being provided to a DP by a Law Firm, Legal Adviser or Counsel, or to Expenses.

2. The payment must be owed in accordance with an obligation which was entered into by the

DP prior to the date of that DP's designation, or in the case of DPs which are owned and

controlled, the owner/ controller of that DP's designation, either under the UK Autonomous

Sanctions Regulations, Council Regulation (EU) No 269/2014 or Council Regulation (EC) No 765/2006 (whichever was earlier).

1. Any professional legal fees and any Counsel's fees paid under this Part in relation to, a DP
   Group or where there is not a DP Group, the designated entity or individual, must not exceed £2,000,000.00 (including VAT if applicable) per Law Firm (or per Counsel, if engaged under a direct instruction) instructed in total for the duration of this licence.

2. The Expenses (including VAT if applicable) paid under this Part in relation to a DP Group or
   where there is not a DP Group, the designated entity or individual, must not exceed (in total) either:

5.1. 10% of the amount payable for professional legal fees and Counsel's fees; or 5.2. £200,000.00;

whichever is lower, for all of the Expenses per Law Firm (or per Counsel, if engaged under a direct instruction) instructed under this Part for the duration of this licence.

1. Where a Law Firm, Legal Adviser or Counsel has not received professional legal fees and/or
   Counsel fees from or on behalf of a DP under this licence, Expenses of up to £50,000 may be paid in relation to a DP Group or where there is not a DP Group, the designated entity or individual, per Law Firm (or per Counsel, if engaged under direct instruction) instructed under this Part for the duration of this licence.

2. If at any point the limits for the professional legal fees, Counsel's fees or Expenses set out
   above are in fact exceeded, Part A of this licence will not apply to any payment of any nature above those limits nor to any other act in relation to the provision of the Legal Services.

3. Any payments made under this Part must:
   8.1. be paid directly to an account held in the UK with a Relevant Institution by a Law Firm,

Legal Adviser, Counsel or a provider of Expenses;

8.2. be paid directly to a Non-UK Bank Account held:-

8.2.1. by a branch of a Law Firm regulated by the Solicitors Regulation Authority, the Law Society of Scotland or the Law Society of Northern Ireland, which provides Legal Services outside the United Kingdom;

8.2.2. by an individual regulated by the Solicitors Regulation Authority, the Law Society of Scotland or the Law Society of Northern Ireland, who provides Legal Services outside the United Kingdom, otherwise than at a branch of a Law Firm that falls within paragraph 8.2.1;

8.3. be paid directly to a Non-UK Bank Account held by Counsel; 8.4. be paid on behalf of a DP to a provider of Expenses by a Law Firm, Legal Adviser or

Counsel, to an account held in the UK with a Relevant Institution by a provider of Expenses, either before or after payment from, for or on behalf of the DP is received.

Reporting

1. Within 14 days of receiving payment for legal services provided to a DP under this licence any Person who has used the licence must send to HM Treasury, by online reporting form:

9.1. The relevant unredacted letter of engagement between the DP and the Legal Adviser,

Law Firm or Counsel;

9.2. Any other document, communication or other record which sets out the obligation

pursuant to which payment is made; and

9.3. The relevant invoice(s) which are being paid. Record-keeping Requirements

1. A DP or Person must keep accurate, complete and readable records, on paper or electronically, of any activity purporting to have been permitted under this licence for a minimum of 6 years.

PART B - LEGAL SERVICES NOT BASED ON A PRIOR OBLIGATION CONDITIONS FOR USE OF THIS PART OF THIS LICENCE- NOTE THAT ALL OF THE BELOW CONDITIONS MUST BE SATISFIED/ COMPLIED WITH.

1. A payment of: 1.1. professional legal fees; and/ or 1.2. Counsel's fees; and/ or 1.3. Expenses,

must be owed by a DP to a Law Firm, a Legal Adviser, Counsel or a provider of Expenses.

1. The payment must be in relation to Legal Services which have been provided, or are being
   provided by the Law Firm, Legal Adviser or Counsel to a DP, or to Expenses.

2. Any professional legal fees and any Counsel's fees paid under this Part in relation to a DP
   Group or where there is not a DP Group, the designated entity or individual, must not exceed £2,000,000.00 (including VAT if applicable) per Law Firm (or per Counsel, if engaged under a direct instruction) instructed in total for the duration of this licence.

3. The Expenses (including VAT if applicable) paid under this Part in relation to a DP Group or
   where there is not a DP Group, the designated entity or individual, must not exceed (in total) either:

4.1. 10% of the amount payable for professional legal fees and Counsel's fees; or 4.2. £200,000.00,

whichever is lower, for all of the Expenses per Law Firm (or per Counsel, if engaged under a direct instruction) instructed under this Part for the duration of this licence.

1. Where a Law Firm, Legal Adviser or Counsel has not received professional legal fees and/or
   Counsel fees from or on behalf of a DP under this licence, Expenses of up to £50,000 may be paid in relation to a DP Group or where there is not a DP Group, the designated entity or individual, per Law Firm (or per Counsel, if engaged under direct instruction) under this Part for the duration of this licence.

2. If at any point the limits for professional legal fees, Counsel's fees or Expenses set out above
   are in fact exceeded, Part B of this licence will not apply to any payment of any nature above those limits nor to any other act in relation to the provision of the Legal Services.

3. The hourly rates for provision of the professional legal fees by a Legal Adviser must not
   exceed those rates listed in paragraph 14 of this Part of the licence in any individual case.

4. The hourly rates to be charged by Counsel must not exceed the rate of £1,500 per hour
   (including VAT).

5. Paragraph 8 does not apply to brief fees or refresher fees in the event that these are fixed
   fees and not subject to hourly rates.

6. If at any point any one hourly rate, for either a Legal Adviser or Counsel exceeds the hourly
   rates set out in this licence, Part B of this licence will not apply to any payment of any nature applying those hourly rates which exceed the rates set out in this licence nor to any other act in relation to the provision of the Legal Services.

7. Any payments made under this Part must either:
   11.1 be paid directly to an account held in the UK with a Relevant Institution by a Law Firm, Legal Adviser, Counsel or a provider of Expenses; 11.2 be paid directly to a Non-UK Bank Account held:-

11.2.1 by a branch, of a Law Firm regulated by the Solicitors Regulation Authority, the Law Society of Scotland or the Law Society of Northern Ireland, which provides Legal Services outside the United Kingdom; 11.2.2 by an individual regulated by the Solicitors Regulation Authority, the Law Society of Scotland or the Law Society of Northern Ireland, who provides Legal Services outside the United Kingdom, otherwise than at a branch of a Law Firm that falls within in paragraph 11.2.1; 11.3 be paid directly to a Non-UK Bank Account held by Counsel; or 11.4 be paid on behalf of a DP to a provider of Expenses, by a Law Firm, Legal Adviser or Counsel to an account held in the UK with a Relevant Institution by a provider of Expenses, either before or after payment from, for or on behalf of the DP is received.

Reporting

1. Within 14 days of receiving payment for legal services provided to a DP under this licence any Person who has used the licence must send to HM Treasury, by online reporting form:

12.1. The relevant unredacted letter of engagement between the DP and the Legal Adviser,

Law Firm or Counsel;

12.2. Details of the name, employment, experience and the years of post-qualification

experience of any Legal Adviser;

12.3. Details of the name, employment, experience and the years of call of any Counsel;

12.4. The relevant invoice(s) which are being paid. Record-keeping Requirements

1. A DP or Person must keep accurate, complete and readable records, on paper or electronically, of any activity purporting to have been permitted under this licence for a minimum of 6 years.

Hourly rates (excluding VAT)

1. LEGAL ADVISERS Other solicitors or legal executives London London London National National Solicitors and legal executives Solicitors and legal executives Trainee solicitors, paralegals and and fee earners of equivalent C Grade A B Fee earner D with over 8 years' experience with over 4 years' experience other fee earners £896 £653 £494 £609 £506 £406 £473 £427 £324 £326 £243 £226 £457 £446 £382 £382 £312 £310 £221 £221 experience

Annex 1 - UK Autonomous Sanctions Regulations Schedules

Regime Relevant Prohibitions Relevant Licensing

The Democratic People's Republic of Korea Regulations 13 to 17 Regulation 88 Authorisation The Republic of Belarus (Sanctions) (EU Exit) Regulations 11 to 15 Regulation 64 The Central African Republic (Sanctions) (EU Exit) Regulations 12 to 16 Regulation 33 The Chemical Weapons (Sanctions) (EU Exit) Regulations 11 to 15 Regulation 20 The Global Anti-Corruption Sanctions Regulations Regulations 11 to 15 Regulation 21 The Global Human Rights Sanctions Regulations Regulations 11 to 15 Regulation 20 The Global Irregular Migration and Trafficking in Regulations 14 to 18 Regulation 26 The Republic of Guinea-Bissau (Sanctions) (EU Regulations 11 to 15 Regulation 20 The Nicaragua (Sanctions) (EU Exit) Regulations Regulations 11 to 15 Regulation 20 The Somalia (Sanctions) (EU Exit) Regulations Regulations 12 to 16 Regulation 47 The South Sudan (Sanctions) (EU Exit) Regulations Regulations 12 to 16 Regulation 33 The Yemen (Sanctions) (EU Exit) (No.2) Regulations 12 to 16 Regulation 33 The Zimbabwe (Sanctions) (EU Exit) Regulations Regulations 11 to 15 Regulation 33 The Bosnia & Herzegovina (Sanctions) (EU Exit) Regulations 11 to 15 Regulation 20 The Democratic Republic of the Congo (Sanctions) Regulations 12 to 16 Regulation 33 The Iran (Sanctions) (Nuclear) (EU Exit) Regulations Regulations 12 to 17 Regulation 40 The Venezuela (Sanctions) (EU Exit) Regulations Regulations 11 to 15 Regulation 35

Regulations Regulations 2019 Regulations 2020 Regulations 2020 Regulations 2019 The Cyber (Sanctions) (EU Exit) Regulations 2020 Regulations 11 to 15 Regulation 20 (Sanctions) (EU Exit) Regulations 2019 (EU Exit) Regulations 2019 Persons Sanctions Regulations 2025 The Guinea (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 Regulation 20 Exit) Regulations 2019 The Iran (Sanctions) Regulations 2023 Regulations 15 to 19 Regulation 60 The Libya (Sanctions) (EU Exit) Regulations 2020 Regulations 12 to 16 Regulation 48 The Mali (Sanctions) (EU Exit) Regulations 2020 Regulations 12 to 16 Regulation 22 The Myanmar (Sanctions) Regulations 2021 Regulations 11 to 15 Regulation 44 The Russia (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 17A Regulation 64 The Sudan (Sanctions) (EU Exit) Regulations 2020 Regulations 12 to 16 Regulation 34 The Syria (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 Regulation 61 Regulations 2020