The Isle of Man Treasury has issued a new general licence for legal services fees under most autonomous financial sanctions regimes as they apply in the Isle of Man, allowing law firms and counsel who have provided legal advice to a designated person to receive payment from that designated person without obtaining a specific licence, provided the licence conditions are met. The licence expands coverage beyond the earlier Russia-focused legal services general licences and applies across the regimes listed in Annex I, including fees and defined expenses for law firms, legal advisers, counsel and expense providers. It does not permit payments made directly or indirectly to or for the benefit of any person designated for the purpose of compliance with United Nations obligations, and it does not authorise any activity that would result in funds or economic resources being made available in breach of the relevant autonomous sanctions regimes except as specifically permitted. The general licence is stated to take effect from 00:01 on 29 October 2025, following the expiry of General Licence IOM/2025/RUS045 on 28 October 2025, and expires at 23:59 on 28 April 2026. Activity conducted under it must be reported to the Treasury within 14 days using the specified reporting forms, and records must be kept for at least six years; the Treasury may vary, revoke or suspend the licence at any time.
The Treasury (Isle of Man) 2025-12-01
Isle of Man Treasury issues general licence allowing payment of legal services fees by designated persons under most autonomous sanctions regimes
The Isle of Man Treasury issued a general licence for legal services fees under most autonomous financial sanctions regimes. It allows law firms and counsel to receive payments from designated persons without a specific licence, provided conditions are met, but excludes payments to those designated under United Nations obligations. The licence is effective from 29 October 2025 to 28 April 2026, with mandatory reporting and record-keeping requirements.