On 19 July, the UK Office of Financial Sanctions Implementation (“OFSI”) issued a general licence (available here) that permits payments by UK air carriers and aircraft operators to Belarus’ air traffic control service Belaeronavigatsia, an entity designated under the UK’s sanctions against Belarus. 

The licence permits payments to Belaeronavigatsia for air traffic services provided pursuant to an emergency situation (being a situation requiring an aircraft to land in or overfly Belarus to avoid endangering the lives of persons or board or the safety of the aircraft).  The licence carries obligations to report details of the payment to OFSI within 14 days, and to keep records for 6 years after the payment is made.

This license is noteworthy as only the second general licence that the OFSI has issued under the UK’s unilateral sanctions regime.  The first licence, issued in January 2021, permitted certain payments to sanctioned Crimean sea ports.

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Sunwinder (Sunny) Mann is a Partner and is Chair of our International Commercial and Trade Global Practice Group. Our Trade team has been ranked Tier 1 by Legal 500 UK for over 20 years. He is currently based in our London office, but has also worked in our offices in Washington, D.C., New York, Sydney and Hong Kong. Sunny's practice focuses on international trade compliance and, in particular, export controls and trade sanctions, as well as anti-bribery. He has worked on a number of significant compliance and investigations matters. He leads our Firm's Geopolitical Risks Taskforce, having coordinated our Firm's support to clients responding to the ongoing Russia crisis.

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