Guidance: OFSI General Licence - INT/2026/10050568

For financial services executives, this is a targeted but important development: it clarifies how property-related payments involving sanctioned persons or entities may be handled. Compliance teams should immediately review the licence conditions, including scope, permitted parties, payment routes, reporting and record-keeping obligations. Banks, payment providers, real estate firms and professional advisers must ensure their sanctions screening and payment approval processes reflect the new licence.

This is not a blanket exemption; payments outside its terms remain prohibited, and firms must continue to apply enhanced due diligence and escalation procedures. Actionable steps include updating policies and procedures, briefing front-line and operations staff, validating customer and counterparty screening alerts, and documenting reliance on the licence. Firms should also consider whether existing payment instructions, property management arrangements or client mandates require remediation.

The guidance may reduce friction for legitimate property-related payments, but it also raises the bar for evidence and audit readiness. Where uncertainty remains, seek legal advice and consider OFSI engagement. Overall, this is a moderate-impact, medium-urgency update requiring prompt operational alignment rather than wholesale strategic change.