New Russia-Related License More Than Triples Cap on Fees Payable to Law Firms

An updated general license issued by the U.K. this week increases the cap on fees that can be paid to British law firms by parties subject to Russia-related sanctions, clarifies how the license applies to in-house lawyers, and more.

The new license, which took effect Oct. 29 after replacing a previous version of the license that expired Oct. 28, increases the "fee and expenses cap" to about $2.59 million per law firm "for the duration of this license," which expires April 28. The previous license had set the fee cap at about $650,000 and the expenses caps at 10% of the legal fees, up to about $65,000.

OFSI also clarified how the fee cap applies to in-house lawyers employed by sanctioned parties. All in-house lawyers working for the same company are subject to the same cap "as if they were, together, a Law Firm."

The license also introduces a "restricted permission to pay into non-UK bank accounts," allowing certain U.K. law firms to receive payments into branch accounts in the U.S., Canada, any EU member state or any European Free Trade Association member state. All funds paid into non-U.K. accounts "must still satisfy the other relevant conditions" of the license, OFSI said.

Any payments received under this license must be reported to the U.K.'s treasury agency within 14 days.