The Isle of Man Treasury has issued a new general licence under most autonomous sanctions regimes as they apply in the Isle of Man, allowing law firms and counsel that have provided legal advice to a designated person to receive payment from that designated person without a specific licence if the licence conditions are met. General Licence IOM/2026/SAN004 follows the expiry of the previous legal services general licence and is effective from 00:01 on 29 April 2026 until 23:59 on 28 October 2026. The licence introduces the new definitions DP Group and Foreign Bank Account and amends the permissions and conditions to reflect them. DP Group covers asset-freeze designees under the autonomous regimes, excluding those designated for compliance with United Nations obligations, together with entities they own or control. Foreign Bank Account covers accounts at supervised institutions in Canada, European Union and European Free Trade Association member states, and the United States. A designated person and its owned or controlled entities may pay legal fees for that designated person or another entity in the same DP Group, and fee and expense caps apply across all matters handled for a DP Group or, where there is no DP Group, the designated individual or entity. Part A applies to legal services based on a prior obligation and Part B to other legal services. Each part separately caps legal and counsel fees at GBP 2 million per law firm or directly instructed counsel, while use of both parts together is capped at GBP 4 million for the life of the licence. Combined expenses are capped at the lower of 10% of those fees or GBP 400,000, or GBP 100,000 where no fees have been received, and Part B also sets graded hourly caps for legal advisers and a counsel rate cap of GBP 1,500 per hour. The Treasury noted that the definitions, permissions and usage requirements do not mirror earlier legal services general licences. Any activity under the licence must be reported to the Treasury within 14 days and records must be kept for at least six years.
The Treasury (Isle of Man) 2026-05-08
Isle of Man Treasury issues six month legal fees general licence under most autonomous sanctions regimes with new DP Group rules
The Treasury of the Isle of Man has issued General Licence IOM/2026/SAN004 under most autonomous sanctions regimes, permitting law firms and counsel to receive payments for legal services from designated persons without a specific licence, subject to conditions. The licence introduces definitions of “DP Group” and “Foreign Bank Account”, revises permissions and conditions, and imposes aggregate fee and expense caps per firm or counsel across all matters for a DP Group or designated person. Users must report activity under the licence to the Treasury and retain records for at least six years.