Guidance

Apply for a licence to provide sanctioned trade services

Check if you need a licence and apply online.

From:
Department for Business and Trade and Office of Trade Sanctions Implementation
Published
10 October 2024
Last updated
31 October 2024 — See all updates

You cannot use the online service on this page to apply for licences for:  

What a services licence allows you to do 

A services licence allows you to provide certain trade services that would otherwise be prohibited under sanctions legislation. 

Prohibited services which can be covered by this licence are:  

  • professional and business services (under the Russia sanctions regime) 

    • accounting 

    • advertising 

    • architectural 

    • auditing 

    • business and management consulting 

    • engineering 

    • IT consultancy and design 

    • legal advisory 

    • public relations 

  • energy-related services (under the Russia sanctions regime), such as drilling, well testing, logging and completion services or the supply of specialised floating vessels  

  • infrastructure or tourism-related services to non-government-controlled Ukrainian territories (under the Russia sanctions regime) 

  • interception or monitoring services (under the Russia, Belarus, Iran, Myanmar, Syria and Venezuela sanctions regimes) 

  • mining, manufacturing or computer services (under the Democratic People’s Republic of Korea sanctions regime) 

  • ships or aircraft-related services (under the Democratic People’s Republic of Korea sanctions regime), such as leasing and chartering, crew services, ship classification services, bunkering or ship supply services 

The sanctions regulations relating to these prohibited services are: 

When you do not need a licence 

 UK sanctions apply to:  

  • all individuals or businesses within the territory and territorial sea of the UK 

  • all UK nationals or UK businesses, wherever they are in the world 

We call this connection to the UK a UK nexus.  

If you have a UK nexus, you do not need a licence to provide services that are either:  

  • not prohibited by sanctions regulations 

  • covered by an exception in sanctions regulations (find information on exceptions in section 3 of the relevant statutory guidance) 

If your business does not have a UK nexus  

If your business does not have a UK nexus, but it has, for example, employees or consultants who have a UK nexus and will be providing the sanctioned services on behalf of the business, you’ll need to apply for a licence for these named individuals only. 

Who is covered by a services licence 

A services licence authorises all named parties to provide the specified services only, for the period stated. 

Once you’re authorised by a licence, you must follow its terms. If you do not, you may be committing a breach of trade sanctions and could be subject to enforcement action.  

You’ll need to select who you want the licence to authorise. A licence authorises either:  

  • a business, or businesses, with a UK nexus (the licence will usually cover all employees, members, partners, consultants, contractors, officers and directors) 

  • named individuals with a UK nexus working for a business with no UK nexus (for example, if your business has no UK nexus and therefore cannot be licensed, but you have employees or consultants with a UK nexus who will be providing the services) 

  • yourself as an individual (for example, if you’re a sole trader and not able to apply under a business with a UK nexus) 

If you’re naming any individuals on the licence, you should get their consent before you apply. 

A third party, such as a legal adviser, can apply on your behalf. They will need to upload a letter of instruction to the application to show they have your permission to act for you. 

Renewing a licence 

You must apply for a new licence if you want to: 

  • renew it 

  • add or remove details that affect the coverage of the licence, such as services, providers or recipients 

What you need to show in your application 

A definition of your services 

You’ll need to describe the specific services you want to provide and show how these align with one, or more, of the definitions of prohibited services in sanctions regulations. To do this, you’ll need to refer closely to the sanctions regulations relevant to you. 

Your purposes for providing these services  

You’ll also need to show how providing your services would be consistent with the purposes of the sanctions.  

These are some activities which the Department for Business and Trade (DBT) considers are likely to be consistent with the purposes of the sanctions, and therefore a licence may be granted for these activities. These pre-defined activities are known as licensing considerations or licensing grounds. If you’re applying under any of these grounds, you’ll need to consider and demonstrate in your application how provision of your services aligns with one, or more, of these grounds. 

You can still apply for a services licence if your services do not align with any of the pre-defined licensing grounds. Instead, you’ll need to show how your services are consistent with the purpose of the sanctions. To do this, you’ll need to refer closely to the Purposes section in Part 1 of the sanctions regulations relevant to you. 

Licensing grounds 

You can find all the pre-defined licensing grounds in the statutory guidance for the sanctions regulations relevant to you. 

For professional and business services supplied under the Russia sanctions, these licensing grounds are: 

  • services necessary for the delivery of humanitarian assistance activity 

  • services in connection with the production or distribution of food, provided this is for the benefit of the civilian population 

  • medical and pharmaceutical purposes, provided this is for the benefit of the civilian population 

  • civil society activities that directly promote democracy, human rights or the rule of law in Russia 

  • services that are necessary for non-Russian persons to divest from Russia, or to wind down business operations in Russia

  • services which are required to enable activities necessary for the urgent prevention or mitigation of an event likely to have a serious and significant impact on human health or safety, including the safety of existing infrastructure or the environment. 

  • services that are necessary for ensuring critical energy supply 

This works differently if you’re providing legal advisory services. A licence may be granted for the provision of legal advisory services where a licensing ground would apply to the activity in relation to which the legal advisory services are being given (the ‘relevant activity’) if the relevant activity was done by a UK person or taking place in the UK.

Different licensing grounds may apply to the provision of services that are not professional or business services (such as interception or monitoring services, or ships and aircraft-related services). Find a list of licensing considerations in the statutory guidance relevant to you: 

Before you start 

You can upload documents that you consider relevant. This might include control structure charts, or detailed plans for divestment or wind-down of operations.  

Ensure you have all the information and documents you need before you start, as you will not be able to save your progress. 

Apply for a services licence 

Start now

If you’re unable to use this service, contact OTSI. 

What happens next  

The licensing body for sanctioned trade services is the Office of Trade Sanctions Implementation (OTSI), part of the Department for Business and Trade (DBT).  

OTSI may contact you if they need further information to assess your application. 

OTSI will tell you whether your licence has been granted or denied.  

You must not engage in any activities prohibited by trade sanctions until a licence has been granted. 

Get help 

If you’re unsure whether this is the right type of trade sanctions licence for your activities, contact OTSI using the enquiry form before submitting your application.

Updates to this page

Published 10 October 2024
Last updated 31 October 2024 + show all updates

  1. The following licensing ground has been removed: services to a person connected with Russia by a UK parent company or UK subsidiary of that parent company 

  2. First published.

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