The key amendment involves refining the criteria for licensing grounds under the UK regime. In particular, OFSI has revised the definitions for "Extraordinary Expenses" and "Extraordinary Situations," ensuring a more precise interpretation and application of these terms.

The guidance, produced by OFSI, offers comprehensive advice on UK financial sanctions. It outlines obligations under financial sanctions and provides insight into OFSI’s approach to licensing and compliance issues. Importantly, it considers relevant case law and guidance at the date of publication.

The updated guidance can be found here.