OFSI General Licence INT/2025/5635700: what changes and who is affected
The UK government’s Office of Financial Sanctions Implementation (OFSI) updated General Licence INT/2025/5635700 to exempt certain oil and energy projects from sanctions controls. The updates specify who or what is exempt and when the exemptions apply, with further amendments in 2026 adding new projects and subsidiaries.
What changed in INT/2025/5635700
The General Licence INT/2025/5635700 defines exemptions for specific oil and energy projects from sanctions rules. Notable recent amendments include: (1) August 6, 2026 – added the Kurdistan Export Pipeline to the list of Exempt Projects; (2) February 24, 2026 – amended to include any entity owned or controlled, directly or indirectly, by PJSC Transneft, following their designation by the UK; (3) December 17, 2025 – added the Zohr project to Exempt Projects. These updates expand which projects and affiliated entities can proceed without triggering certain sanctions provisions. See the official GOV.UK notice for precise wording and scope.
Who is affected by the licence changes
Entities involved in exempt oil and energy projects listed in the licence, or those owned or controlled by designated entities (such as PJSC Transneft after the 2026 designation), may operate under the exemptions when conducting qualifying activities. This can include project developers, operators, suppliers, and financiers tied to the listed projects. The licence does not automatically remove all risk; it specifies conditions under which certain activities may proceed without breaching sanctions rules.
Practical next steps for organisations
1) Review the full OFSI General Licence INT/2025/5635700 text on GOV.UK to confirm whether your project or counterparties are listed as Exempt Projects or are owned/controlled by an exempt entity. 2) If relevant, map your activities to the licence’s allowed actions and note any prohibited activities or monitoring requirements. 3) Check for any additional 2025–2026 amendments that may affect your structure, including entities linked to designations such as Transneft. 4) Maintain documentation showing compliance decisions and the basis for exemption in case OFSI requests evidence. 5) Consider seeking legal advice if your organisation spans multiple jurisdictions or involves complex ownership chains.
Limits and open questions
While the licence provides exemptions for specific projects and entities, it does not cover all sanctions scenarios. The scope may be limited to particular activities, geographies, or time frames, and future amendments could alter who qualifies. If you are uncertain whether your activity is exempt, consult the official guidance and consider formal OFSI guidance or legal counsel to resolve ambiguities.
Which sources did Setup in Bahrain review?
Setup in Bahrain reviewed the following source material before preparing this explanatory article.
The links remain visible so readers can inspect the evidence, compare dates and context, and confirm current requirements with the relevant authority.
- gov.uk — evidence source reviewed for this article.
Information and responsibility notice: This article is general information based on the cited material available when published. It is not legal, tax, immigration, medical, financial, banking, or investment advice; it does not create a professional-client relationship; and it is not a guarantee of outcome, availability, accuracy, or eligibility. Rules, schedules, prices, and third-party information can change. Confirm material decisions with the relevant authority and an appropriately qualified adviser before acting.