On 30 June, a post from the OFSI blog was concerned with applying for a licence from the Office of Financial Sanctions Implementation to release otherwise frozen funds for legal fees or the maintenance of frozen funds or economic resources, and the term “reasonableness”. OFSI is legally obliged to ensure that those fees and expenses are “reasonable”. There are 2 licensing derogations that include a ‘reasonableness’ test – ‘legal services’ and ‘maintenance of funds or frozen resources’. The post outlines the types of questions that applicants may wish to consider when applying under these specific licensing grounds. The term ‘reasonable’ is a legal requirement both for OFSI to assess this and for applicants to provide evidence of why a payment is reasonable.
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