UK Issues General License for Provision of Legal Services Under Russia, Belarus Sanctions Regimes

The U.K. released a General License under its Russia and Belarus sanctions regimes pertaining to the provision of legal services, the Office of Financial Sanctions Implementation announced. The license allows for the payment of legal fees by designated individuals and entities to law firms and counsel. The license distinguishes between legal fees issued pre- and post-designation. OFSI imposed a cap of around $574,000, VAT included, on the amount that can be claimed for legal work carried out pre-designation, and an identical cap on overall fees for legal work started post-designation with reporting obligations proving all fees are reasonable.

These two caps can be combined, and any fees above these caps must be approved via a specific license. General license users must submit a report to OFSI when their use of the license has ended or for work carried out under the license when the license expires. Users of the general license must keep records of using the license for six years, OFSI said. The license further lays out hourly rate caps, excluding VAT, for legal advisers and sets a cap of $1,723 per hour for counsel, including VAT. A cap is also set on the expenses associated with the provision of legal services, which is 5% of legal fees per derogation. The license expires April 28, 2023.