Latest General Licence Under Russian Sanctions Published by FRA

Because the prior licence has expired, firms that relied on it must confirm whether they fall within the new permission and update sanctions procedures before any further activity. Compliance teams should treat this as a controlled permission, not a blanket exemption: verify the fund/manager classification, document eligibility, and apply the licence conditions narrowly. Operationalise the two reporting streams immediately—notify the Governor as soon as practicable on first reliance and submit monthly activity reports on the 16th.

Legal, compliance and fund operations should agree a first-use escalation route, maintain evidence of permitted payments, and reconcile frozen-account activity. Boards should also monitor for any replacement or expiry and assess whether investor communications are needed. The licence reduces disruption for affected Cayman funds but leaves sanctions exposure high if conditions or reporting deadlines are missed.