Licensing Delegation Framework for Counter Terrorism
Updated 21 October 2024
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The Delegation Framework (“DF”) elaborates on circumstances that do not constitute a ‘significant change’ for new licences or amendments to existing licences, wherein the Minister has previously delegated the power to make a licensing decision to a Senior Civil Servant (”SCS”). Applications for new licences or amendments which involve a significant change to the DP’s authorisations or obligations in respect of those authorisations under the Counter Terrorism (“CT”) regimes will be considered contentious by default and will therefore require Ministerial approval.
This framework also outlines the current process in CT for issuing breach letters. CT caseworkers should use this framework to determine the appropriate decision maker.
SCS sign off
OFSI’s delegated framework authorises SCS sign off for the following licence applications:
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Access to state benefits from Government agencies such as DWP.
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Repayment of over -payments, fees, refunds etc. from previously licenced sources with the legal and policy risk assessed as low.
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One-off low risk activity – situations sometimes arise that require licences which are uncontroversial in nature, which are consistent with previous Ministerial decisions, and where both the policy and legal risk are assessed as low. For example, requiring a new washing machine. In these circumstances a receipt would be provided to confirm proof of purchase.
CT unit head sign off
The OFSI’s Head of CT (G6) is able to sign off the following licence amendment applications:
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Corrections to licences arising from typographical errors, with the exception of values or where the amendment would materially change the terms of the licence.
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Administrative amendments: for example, minor changes to update bank details for approved suppliers or the DP’s account; or
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Amendments where no additional funds are made available to the DP and where their licensing permissions remain the same e.g. only an extension to the licence period is required.
Breach letters which state no further action will be taken are to be signed off by OFSI’s Head of CT. However, other types of breach letters will have SCS oversight before they are issued given that these carry a higher potential reputational and legal risk. If a breach is considered particularly contentious it will be escalated to the Director of OFSI.