UK Sanctions Insurance Payments General Licence
Summary
OFSI issued General Licence INT/2022/2009156 permitting specific insurance-related payments that would otherwise breach UK Autonomous Sanctions Regulations. The licence authorises UK insurers, insurance brokers, and regulated financial institutions to process premiums, claims, and refunds involving designated persons for specified insurance products covering UK properties and motor vehicles.
What changed
This General Licence grants exemptions from asset freeze prohibitions under UK Autonomous Sanctions Regulations for permitted insurance payments. The licence covers buildings insurance, terrorism cover, property owners' liability, claims preparation costs, engineering insurance, employers' liability insurance, and motor insurance for vehicles ordinarily kept in the UK. It also authorises return payments including claim payouts to designated persons, premium refunds, and repayment of insurance premium finance.
UK insurers, insurance brokers, and Relevant UK Institutions may process these payments without violating sanctions prohibitions, provided they comply with conditions specified in the licence. Property owners with sanctioned tenants can now maintain required insurance coverage. No compliance deadline is specified as this is a standing general licence authorising ongoing activities.
Source document (simplified)
GENERAL LICENCE: Permitted Payments to UK Insurance Companies INT/2022/2009156
This licence is granted under all UK Autonomous Sanctions Regulations listed in Annex I of this
licence.Any act which would otherwise breach the prohibitions in the UK Autonomous Sanctions
Regulations, as listed in Annex I of this licence, is exempt from those prohibitions to the extent required to give effect to the permissions in this licence.In this licence:
"Permitted Payments" means Insurance premiums, reinsurance premiums, Insurance
Premium Finance and broker commissions relating to the
provision of:
- In relation to UK properties -
- Buildings Insurance,
- Terrorism Cover,
- Property Owners' Liability Insurance,
- Claims Preparation Costs Insurance,
- Engineering insurance,
- Employers' Liability Insurance, and 2. Motor Insurance provided to motor vehicles ordinarily kept in the UK. "UK DPs" means Those individuals or entities designated (or owned or controlled "Return Payments" means 1. Payments due as a result of a successful claim made by an individual or an entity designated) for the purposes of an 3. Repayment of Insurance Premium Finance to a against an insurance policy provided by the UK Insurers; The "UK Insurers" means A firm with permission to effect or carry out contracts of insurance "UK Insurance Brokers" means a firm carrying on insurance distribution activity other than an asset freeze by the UK under the UK Autonomous Sanctions "the UK Autonomous Sanctions Sanctions regulations made under the Sanctions and Anti-Money "Person" means An individual or a body of persons corporate or Relevant UK Institution or UK Insurers or UK and or reinsurance in the UK and registered by the Financial Conduct insurer in the UK and registered by the Financial Conduct Regulations, excluding those designated for the purpose of Regulations" means Laundering Act 2018 (the Sanctions Act) listed in Annex I of this unincorporate but does not include a UK DP or UK Insurance Insurance Brokers. 2. Refunds made pursuant to this licence resulting from: compliance with United Nations obligations. Brokers. Authority (FCA). Authority (FCA). licence.
a "Relevant UK Institution" A person that has permission under Part 4A of the Financial means Services and Markets Act 2000(3) (permission to carry on regulated activity). A person that is authorised or registered under Part 2 of the Payment Services Regulations (SI 2017/752). Permissions A person that is authorised or registered under Part 2 of the Electronic Money Regulations (SI 2011/99). 4. Under this licence, subject to the conditions in Paragraphs 8-10 9-11 below:
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 "Insurance Premium Funds provided by a Relevant UK Institution for the a. An overpayment of an insurance premium, reinsurance
"Property Owners' Liability Insurance covering claims made against landlords and property Finance" means purpose of payment for Motor Insurance including: "Employers' Liability Insurance covering the cost of claims made against an Act 2000. premium or broker commission,
Insurance" means owners in respect of their legal liability for personal injury or "Claims Preparation Costs Insurance covering the cost of appointing a professional claims "Engineering Insurance" means Insurance against risks associated with erection, resting and Insurance" means employer by employees for bodily injury or disease A person that is an operator of a recognised payment system (or a) Policy Premiums b. Cancellation of a policy,
"Buildings Insurance" means Insurance covering the cost of repairing damage to the structure "Terrorism Insurance" means Insurance covering the cost of repairing damage to the structure "Motor Insurance" means A contract of insurance within the motor vehicle liability or land property damage suffered by third parties and arising from the that is a service provider in relation to recognised payment working of any machinery, plant or equipment in commercial Insurance" means handler to deal with any claims made against an insurance policy arising out of and in the course of their employment in b) Excesses c. A change of risk, or d. A no claims bonus in relation to motor insurance. of a property as a result of an act of terrorism. of a property. vehicle class. policyholder's ownership of the property. permitted under this licence. properties, including those being let by a UK DP. Great Britain in the business. systems) for the purposes of Part 5 of the Banking Act 2009 c) Credit Interest Payments.
4.1 UK DPs may make Permitted Payments to UK Insurers and Relevant UK Institutions from a frozen UK bank account; 4.2 Persons acting on behalf of UK DPs may make Permitted Payments to UK Insurers and
Relevant UK Institutions.
4.3 Where a Permitted Payment is made by a Person acting on behalf of a UK DP: 4.3.1 UK DPs may repay that Person from a frozen UK account the same amount as that Permitted Payment; 4.3.2 The Person may receive that amount from UK DPs; and 4.4 UK Insurers and Relevant UK Institutions may receive the Permitted Payments.
Under this licence, subject to the conditions in Paragraphs 8-10 9-11 below:
5.1 UK Insurers and Relevant UK Institutions may make Return Payments to DPs to frozen UK bank accounts; 5.2 UK Insurers and Relevant UK Institutions may make refunds due as a result of overpayments to a Person who has made a Permitted Payment to them under paragraph 4.2; and 5.3 UK DPs may receive Return Payments from UK Insurers and Relevant UK Institutions into a frozen UK bank account.Under this licence, subject to the conditions in Paragraphs 9-11 below:
6.1 UK DPs may make Permitted Payments to UK Insurers, Relevant UK Institutions and UK Insurance Brokers from a frozen bank account; 6.2 Persons acting on behalf of UK DPs may make Permitted Payments to UK Insurance Brokers and Relevant UK Institutions; 6.3 UK Insurers, UK Insurance Brokers may transfer funds received under paragraphs 6.1 and 6.2 to UK Insurers; 6.4 UK Insurers, UK Insurance Brokers and Relevant UK Institutions may receive Return Payments from UK Insurers due to UK DPs; 6.5 UK Insurers, UK Insurance Brokers and Relevant UK Institutions may make refunds due as a result of overpayments to a Person who has made a Permitted Payment to them under paragraph 6.2; 6.6 UK Insurers, UK Insurance Brokers and Relevant UK Institutions may make Return Payments to DPs to frozen UK bank accounts; and 6.7 Relevant UK Institutions may transfer funds received under paragraphs 6.1
and 6.2 to UK Insurance Brokers and UK Insurers.
A Relevant UK Institution may process payments made in accordance with paragraphs 4, 5 and 6
aboveThis licence does not permit the provision of insurance to those also designated by the United
Nations.
Reporting Requirements
Within 10 working days of making a transaction under this General Licence, the DP must report to
HM Treasury, with details and supporting evidence of:The name of the Relevant UK Institution providing the financial agreement for
Insurance (where applicable);
- The name of the UK Insurer;
- The amount(s) transferred;
- The payment route used; and
The date on which the funds were transferred.
Within 10 working days of making a Return Payment to a DP under this General Licence, the UK
Insurers or, Insurance UK Brokers and Relevant UK Institutions who made that payment directly to the DP must report to HM Treasury, with details and supporting evidence of:The amount(s) transferred;
The payment route used;
The date on which the funds were transferred; and
The name of the DP to whom the payment is made.
Record-keeping RequirementsThe UK Insurers, UK Insurance Brokers, Relevant UK Institutions and UK DPs 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. GeneralThe permissions in this licence do not authorise any act which 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.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.This licence takes effect from 22 July 2022.
HM Treasury may vary, revoke or suspend this licence at any time.
Signed:
Office of Financial Sanctions Implementation HM Treasury
22 July 2022
Amended 17 August 2022 Amended 15 December 2023 Amended 06 February 2024 Amended 15 February 2024 Amended 09 August 2024 Amended 11 September 2025 Amended 31 March 2026.
Annex 1 - UK Autonomous Sanctions Regulations Schedules
The Democratic Republic of the Congo (Sanctions) (EU Exit) Regulations 12 to 16 The Global Irregular Migration and Smuggling in Persons Regulations 14 to 18 The Republic of Guinea-Bissau (Sanctions) (EU Exit) Regulations Regulations 11 to 15 The Russia (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 and/or The Central African Republic (Sanctions) (EU Exit) Regulations Regulations 12 to 16 The Counter-Terrorism (International Sanctions) (EU Exit) Regulations 11 to 15 The Democratic People's Republic of Korea (Sanctions) (EU Exit) Regulations 13 to 17 The Republic of Belarus (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 The Burundi (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 The Chemical Weapons (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 (Sanctions) Regulations 2025 The Iran (Sanctions) (Nuclear) (EU Exit) Regulations 2019 Regulations 12 to 17 The Myanmar (Sanctions) Regulations 2021 Regulations 11 to 15 The South Sudan (Sanctions) (EU Exit) Regulations 2019 Regulations 12 to 16 The Syria (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 The Yemen (Sanctions) (EU Exit) (No.2) Regulations 2020 Regulations 12 to 16 Regime Relevant Regulations The Bosnia & Herzegovina (Sanctions) (EU Exit) Regulations 2020 Regulations 11 to 15 Regulations 2019 The Counter-Terrorism (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 The Cyber (Sanctions) (EU Exit) Regulations 2020 Regulations 11 to 15 Regulations 2019 Regulations 2019 The Global Anti-Corruption Sanctions Regulations 2021 Regulations 11 to 15 The Global Human Rights Sanctions Regulations 2020 Regulations 11 to 15 The Guinea (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 The Iran Human Rights (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 The Libya (Sanctions) (EU Exit) Regulations 2020 Regulations 12 to 16 The Nicaragua (Sanctions) (EU Exit) Regulations 2020 Regulations 11 to 15 17A The Somalia (Sanctions) (EU Exit) Regulations 2020 Regulations 12 to 16 The Sudan (Sanctions) (EU Exit) Regulations 2020 Regulations 12 to 16 The Venezuela (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15 The Zimbabwe (Sanctions) (EU Exit) Regulations 2019 Regulations 11 to 15
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