OFSI Publishes Seven-Criteria Framework for Prioritising Sanctions Licence Applications

OFSI remains committed to a transparent, fair and effective licensing process. Publishing this prioritisation framework is part of our continuing efforts to ensure that applicants understand how we assess cases and what they can do to support timely decision‑making.

OFSI receives a wide variety of licence applications each year, ranging from urgent humanitarian requests to complex commercial transactions. In the financial year 2024-2025, OFSI took over 900 licensing decisions. It is not possible to deal with all applications as soon as they are received. Publishing our prioritisation framework aims to help applicants understand how OFSI manages competing demands and how applications are prioritised.

Each licence application is assessed against seven criteria as set out below. These criteria help caseworkers understand urgency, risk, stakeholder impact and possible harm caused by delay. Applications are then categorised as high, medium or low priority.

While the framework provides structure, OFSI caseworkers continue to use professional judgement and may adjust prioritisation where circumstances require a different approach. Additionally, even if a licence application is prioritised as urgent, complexities may mean it still takes time to complete. Applicants should therefore submit licence applications well in advance of when they are needed, wherever possible.

The Criteria

1. Nature of the licensing purpose

Humanitarian applications, basic needs, or anything where delay could significantly affect access to justice (i.e. where there are court dates which must be complied with) are generally treated as high priority.

Generally, you won’t be prohibited from providing legal advice under an asset freeze. However, the payment for legal services and the provision of legal services on credit do require an OFSI licence. On that basis, applications may not immediately be considered as a high priority. OFSI has issued a Legal Services General Licence to allow payments for legal fees within certain limits and under certain conditions. It is recommended that you consult the Legal Services General Licence prior to an application to OFSI to determine whether that General Licence would be applicable to you.

2. Materiality to the applicant or affected parties

OFSI assesses how significant the application is in real terms. This includes the applicant’s circumstances, the size of the transaction relative to their means, and whether delay would result in economic loss.

3. Timing considerations

Applications may be prioritised where a decision is genuinely time‑sensitive, where delays would cause harm, or where the application has already been outstanding for a significant period.

4. UK economic impact

Applications that may affect UK jobs, business continuity or wider economic welfare may be prioritised.

5. Administrative impact on OFSI

Some cases may affect OFSI's ability to progress other applications — for example, those forming part of a series of related applications.

6. Reputational or strategic impact

Applications may be prioritised where delay could undermine confidence in the UK sanctions regime, affect relationships with key partners, or have significant implications for foreign policy, national security or energy security.

7. Complexity of the application

Complex or precedent‑setting cases may require more time and scrutiny. These may be prioritised to ensure consistent and robust decision-making. However, even when a case is prioritised in accordance with this criterion, an application may still take time to complete.

How the criteria work in practice

High‑priority cases generally meet at least two of the criteria at a high level -humanitarian cases, or cases where a risk to life has been demonstrated, are almost always classified as high priority. Medium‑priority cases demonstrate a moderate level of impact across several criteria. Low‑priority applications generally show limited impact in most areas.

Caseworkers may adjust priority where individual circumstances justify doing so.

These criteria only assist in the prioritisation of applications and do not create an automatic right to priority or expediency. The outcome of this assessment does not affect the outcome of the application and there may still be a number of applications which have been categorised with the same urgency.

How applicants can support the process

Applicants can help OFSI process their applications more efficiently by submitting clear, complete and well‑evidenced information. Here are some steps that will help:

• Provide a clear legal basis
  Applicants should set out the specific licensing ground that applies and explain  how their circumstances meet it.

• Include all required information upfront
  Missing or unclear information is one of the most common causes of delay. Applicants should provide evidence of urgency, where applicable, to assist in the prioritisation of applications.

• Avoid repeat or speculative applications
  Submitting an application again without new information, or submitting entirely speculative applications “just in case”, may delay processing and is unlikely to result in the case being prioritised as high priority. You may wish to seek legal advice in advance of making an application and check whether any General Licences apply to your situation.

• Highlight genuine deadlines
  Where a deadline exists—such as a court date or risk of hardship—applicants should clearly explain and evidence this in their application.

• Use OFSI’s online application form
  Using OFSI’s online application form will ensure that cases are received by the correct team as early as possible and could prevent any additional delays

OFSI is unable to provide legal advice to applicants and if you are in any doubt, you should seek independent legal advice in relation to the matters raised. You may also wish to consult OFSI’s other guidance products, such as:

• How to apply for a financial sanctions licence - GOV.UK

• Reasonableness in licensing – Office of Financial Sanctions Implementation

• Permitted travel expenses for sanctions licence applications - GOV.UK
  Tags: Licensing

Sharing and comments

Share this page

• X (formerly Twitter)
• Facebook
• LinkedIn
• Email

Related content and links

About OFSI

OFSI helps ensure financial sanctions are properly understood, implemented and enforced in the United Kingdom. This includes the Oil Price Cap on Russian oil.

OFSI is part of HM Treasury.

---

Sign up and manage updates

---

Follow us

---

Comments and moderation

Read our guidelines.