News
New framework for prioritising sanctions licence applications
12 March 2026
The Office of Financial Sanctions Implementation (OFSI) has published guidance on how it prioritises licence applications. OFSI receives a wide variety of licence applications each year, ranging from urgent humanitarian requests to complex commercial transactions. It has published its prioritisation framework to help applicants understand the process.
As a solicitor or compliance officer, this guidance will help you to:
- judge timelines for action
- explain and manage client expectations
- avoid unnecessary resubmissions.
Each licence application is assessed against seven criteria. These criteria help caseworkers understand urgency, risk, stakeholder impact and possible harm caused by delay.
- Nature of the licensing purpose.
- Materiality to the applicant or affected parties.
- Timing considerations.
- UK economic impact.
- Administrative impact on OFSI.
- Reputational or strategic impact.
- Complexity of the application.
Generally, applications on humanitarian grounds, where a risk to life is demonstrated, or which involve deadlines such as court dates will be treated as highest priority.