The UK Office of Financial Sanctions Implementation (OFSI) has updated its general guidance on financial sanctions, introducing a new licensing ground under Section 6.6, permitting the return of funds from designated Money Service Businesses (MSBs) to non-designated persons, subject to strict conditions. To qualify, the MSB must be registered in the UK under the Money Laundering Regulations 2017, the recipient must not be a designated person and no payments will be made to a designated person (whether directly or indirectly), the original payment must have been made prior to the MSB's designation without breaching asset freeze restrictions and the repayment must not undermine efforts to prevent or detect serious crime. OFSI will consult law enforcement authorities to assess crime risk before granting a licence, and only MSBs defined and registered under the 2017 Regulations are eligible. OFSI emphasises that as licensing grounds and exceptions can vary between regimes, it remains essential to consult the relevant, up-to-date legislation.
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