UK Updates Definitions of Extraordinary Situations, Expenses for Sanctions Licenses

The U.K. amended its definitions for "extraordinary situations and extraordinary expenses" under the Office of Financial Sanctions Implementation's general sanctions guidance related to the agency's approach to licensing grounds.

Extraordinary expenses "must be extraordinary in nature (including, but not limited to, unexpected, unavoidable and/or non-recurring)." The definition clarified that the designation can't be used where other licensing grounds are "more suitable" or as a way of skirting the clear limits on those other grounds.

Extraordinary situations "must be extraordinary in nature," applying to "non-UN designated persons" and enabling "anything to be done to deal with an extraordinary situation." This will let a license be issued to deal with a situation that is "extraordinary in nature but does not necessarily involve an expense."

OFSI said there's a "high threshold for a situation to meet the standard of being extraordinary."