Question to the HM Treasury:
To ask Her Majesty's Government what is the median time taken to determine licence applications to permit payment for legal (1) advice, or (2) representation.
The Office of Financial Sanctions Implementation (OFSI) in HM Treasury is responsible for financial sanctions enforcement. OFSI may issue a licence to enable the payment of reasonable fees and/or expenses for the provision of legal services. Providing legal services to a designated person or entity subject to financial sanctions restrictions is not prohibited, a licence is only required to permit payment for these services.
OFSI aims to engage with the substance of licence applications within 4 weeks, however application times can vary where further information is required.
From June 2021 to June 2022 OFSI issued 29 licences for the payment of legal fees. OFSI is unable to provide all of the information requested as it does not collate information on legal expenses licence applications broken down by (a) legal advice and (b) legal representation, or by the involvement of sanctioned (1) individuals or (2) entities, or by the live status of the application, and it would involve disproportionate costs to gather.
The number of active staff in OFSI since Financial Year 2016-2017 can be found in the table below:
Financial Year | Total number of staff |
2016-2017 | 27 |
2017-2018 | 30 |
2018-2019 | 36 |
2019-2020 | 38 |
2020-2021 | 40 |
In light of recent developments in Ukraine, the number of staff has since increased. Releasing further details of OFSI’s headcount by function could prejudice its operational effectiveness.
OFSI publishes an Annual Review containing information on the breakdown of legal expenses licences issued during the preceding financial year. The 2020/21 Annual Review can be found on gov.uk. Data for the 2021/22 financial year is expected to be published in the Autumn and this will include a further update of total OFSI headcount.