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Routine Notice Amended Final

General Licence allowing sanctioned UK persons to pay utility bills

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Published February 29th, 2024
Detected April 4th, 2026
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Summary

OFSI published notice regarding General Licence INT/2022/2300292 allowing UK designated persons subject to asset freezes to make permitted utility payments for gas and electricity from frozen UK bank accounts. The General Licence, originally issued November 2022, has been amended multiple times to expand permissions, most recently February 2024 to include additional permitted payment categories for gas and electricity meters.

What changed

OFSI issued General Licence INT/2022/2300292 under UK Autonomous Sanctions Regulations, permitting sanctioned UK persons (UK DPs) to pay gas and electricity bills from frozen bank accounts to OFGEM-registered Energy Companies. The licence defines Permitted Payments to include utility services, meter-related activities, and Return Payments for overpayments or government energy subsidies. Subsequent amendments added permissions for third parties to make payments on behalf of DPs, expanded coverage to Russia Regulations (Regulation 17A), and added meter installation and monitoring payments. Energy Companies may receive and return payments to frozen accounts through bank transfer or direct debit via Relevant UK Institutions.

UK DPs and Energy Companies using this licence must comply with reporting and record-keeping requirements set out in the General Licence. Any person intending to use the licence should consult the full document on the OFSI webpage for complete permissions, conditions, and usage requirements. Energy Companies receiving payments are not required to freeze legitimate utility income from sanctioned persons.

What to do next

  1. Consult the full General Licence INT/2022/2300292 on the OFSI webpage for complete permissions and conditions
  2. Review reporting and record-keeping requirements applicable to UK DPs and Energy Companies
  3. Ensure payment mechanisms comply with specified methods (bank transfer or direct debit through Relevant UK Institutions)

Source document (simplified)

General Licence - Publication Notice General licence - INT/2022/2300292 OFSI has the power to issue General Licences for country sanctions regimes under the Sanctions and Anti-Money Laundering Act 2018 ("the Sanctions Act"). On 17 November 2022, OFSI issued General Licence INT/2022/2300292 under all UK Autonomous Sanctions Regulations (see Annex 1 of the General Licence for the list of relevant Regulations) which allows for payment to utility companies for gas and electricity by UK designated persons who own or rent properties in the UK. Any persons intending to use General Licence INT/2022/2300292 should consult the copy of the Licence on this webpage for full details of the permissions and usage requirements. For the purposes of General Licence INT/2022/2300292: Energy Companies mean OFGEM registered firms with permission to provide gas and/or electricity to properties in the UK. UK DPs mean individuals or entities designated (or owned or controlled by an individual or an entity designated) for the purposes of an asset freeze by the UK under the UK Autonomous Sanctions Regulations Regimes only, excluding those designated for the purpose of compliance with United Nations obligations but not those sanctioned by the United Nations. Return Payments means payments due as a result of over-payments made pursuant to this licence or in relation to the UK Government energy subsidy payments under the Energy Bills Support Scheme over winter 2022 to 2023 Energy Bills Discount Scheme (EBDS) (which closed on 31 March, 2024). Permitted Payments means:

  • Utility payments for gas and electricity supplies and heating and/or hot water powered by
    gas or electricity from an external source, such as through a district heating network, to UK properties owned or rented by UK DPs.

  • Payments for gas and electricity meter installation, certification, validation, monitoring,
    replacement, removal, including meters related to district heating networks, and other payments in relation to these activities. Relevant UK Institution means:

  • A person that has permission under Part 4A of the Financial Services and Markets Act 2000
    (permission to carry on regulated activity).

  • A person that is authorised or registered under Part 2 of the Payment Services Regulations
    (SI 2017/752).

  • A person that is authorised or registered under Part 2 of the Electronic Money Regulations
    (SI 2011/99).

  • A person that is a "recognised clearing house", "third country central counterparty",
    "recognised CSD" or "third country CSD" for the purposes of s.285 of the Financial Services

and Markets Act 2000.

  • A person that is an operator of a recognised payment system (or that is a service provider in
    relation to recognised payment systems) for the purposes of Part 5 of the Banking Act 2009. Under General Licence INT/2022/2300292 UK DPs may make Permitted Payments to Energy Companies from a frozen UK bank account by bank transfer or by direct debit; Energy Companies may receive the Permitted Payments; Energy Companies may make Return Payments to frozen UK bank accounts and UK DPs may receive Return Payments from Energy Companies into a frozen UK bank account. The reporting and record-keeping requirements for UK DPs and Energy Companies are set out in the General Licence. On 13 October 2023, General Licence INT/2022/2300292 was amended to:

  • Add a definition of a Person;

  • Add Permission 4.3 which allows a Person to make Permitted Payments to Energy
    Companies for or on behalf of a DP or for the benefit of a DP; and

  • Expand the list of the UK Autonomous Sanctions Regulations Schedules contained within
    Annex 1 so that all the relevant Regulations are included. On 15 December 2023, the General Licence was amended to also permit activity that would otherwise breach the prohibitions in Regulation 17A of the Russia Regulations. On 29 February 2024, the General Licence was amended to add a permission to the list of Permitted Payments:

  • Payments for gas and electricity meter installation, certification, validation, monitoring,
    replacement, removal and other payments in relation to these activities. On 28 October 2024, the General Licence was amended to:

  • Make clear that the definition of UK DPs includes entities owned or controlled by a
    designated individual or entity; and excludes those designated for the purpose of compliance with United Nations obligations.

  • Add heating and/or hot water powered by gas or electricity from an external source such as
    through a district heating network; and meters related to district heating networks to the "Permitted Payments" definitions section.

  • Update the reference to the Energy Bills Discount Support Scheme (EBDS) in the "Return

Payments" definitions section.

  • Update the list of the UK Autonomous Sanctions Regulations Schedules contained within
    Annex 1 so that all the relevant Regulations are included. On 26 September 2025, this licence was amended such that:

  • Reference to frozen UK bank accounts has been removed from Permission 4.1 to make clear
    that payments by DPs are not restricted to those made from frozen funds;

  • The reporting conditions have been updated to be submitted: "Within 30 days of the end of
    a Yearly Quarter" (refer to paragraph 8 of the General Licence); and,

  • Annex 1, Schedule of UK Autonomous Sanctions Regulations, now includes the Global
    Irregular Migration and Trafficking in Persons Sanctions Regulations 2025.

On 31 March 2026, this licence was amended such that:

  • Reference to payments required to be by bank transfer or by direct debit were removed from Permission 4.1 to make it clear that payments by DPs are not restricted to these payment methods.

General

The permissions in General Licence INT/2022/2300292 do not authorise any act which the person carrying out the act knows, or has reasonable grounds for suspecting, will result in funds or economic resources being made available in breach of the relevant UK Autonomous Sanctions Regulations, save as permitted under a licence granted under those Regulations General Licence INT/2022/2300292 took effect on 17 November 2022. On 24 February 2023 it was extended with an expiry date of 23:59 on 16 October 2023. On 13 October 2023 the General Licence was extended and no longer has an expiry date.

Office of Financial Sanctions Implementation HM Treasury

Named provisions

Permitted Payments Return Payments Relevant UK Institution Regulation 17A - Russia Regulations

Source

Analysis generated by AI. Source diff and links are from the original.

Classification

Agency
OFSI
Published
February 29th, 2024
Instrument
Notice
Legal weight
Binding
Stage
Final
Change scope
Minor
Document ID
INT/2022/2300292

Who this affects

Applies to
Financial advisers Energy companies Consumers
Industry sector
2210 Electric Utilities
Activity scope
Sanctions Compliance Energy Utility Payments Payment Processing
Threshold
Individuals or entities designated under UK Autonomous Sanctions Regulations (excluding those designated solely for UN compliance)
Geographic scope
United Kingdom GB

Taxonomy

Primary area
Sanctions
Operational domain
Compliance
Compliance frameworks
OFAC Sanctions
Topics
Banking Energy

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