UK Issues General License Under Russia Sanctions Regime Covering Legal Fees

The U.K. issued a General License under its Russia and Belarus sanctions regimes permitting sanctioned individuals and entities to pay legal fees to law firms and counsel. The license took effect on April 29 and permits these payments in relation to any matter, except defamation or malicious falsehood proceedings, until Oct. 28. The license distinguishes between legal services issued pre-listing and post-listing.

The U.K. put a more than $625,000 cap on the amount that can be claimed for legal work carried out pre-listing and a cap of 5% of the legal fees on expenses linked with the provision of legal services. A $625,000 cap also was imposed on overall fees for legal work initiated post-listing, with the same 5% cap applying to expenses. The license also sets a limit on what hourly rate a legal adviser can set.

Parties that use the license must provide a report to the Office of Financial Sanctions Implementation when use of the license has ended or when the license expires for work paid under the license. These parties also must keep records of "any activity purporting to have been permitted under this" license for no less than six years.