Sanctions prohibitions are written broadly and licences are how the exceptions are made. There are two kinds, and the difference between them is who has to ask.
The two kinds
OFAC’s regulations describe the arrangement in 31 CFR 501.801. General licences authorise “certain types of transactions” that would otherwise be prohibited, “under appropriate terms and conditions”. They are published on OFAC’s website or in the Federal Register, and anyone who fits the terms can rely on one without applying. Specific licences cover transactions not authorised by a general licence and are issued to an applicant who has filed for one, naming all parties interested in the transaction. OFAC’s stated policy is not to grant a specific licence for a transaction a general licence already covers.
OFSI in the UK describes the same idea in its own notices. In a 2025 penalty notice it defines a general licence as one that “allows multiple parties to undertake specified activities which would otherwise be prohibited by sanctions legislation, without the need for a specific licence”.
Conditions are part of the licence
The reason this belongs on a page about evasion is that a general licence is easy to treat as permission and easy to lose track of. Two documented examples:
- Reporting. OFAC’s regulations warn that persons relying on certain general licences may have to file reports, and that failure to file on time “may nullify the authorization otherwise provided by the general license and result in apparent violations”. OFSI’s Colorcon penalty in 2025 is the same point from the UK side. Colorcon’s Moscow office made 123 payments through accounts at designated banks, and OFSI treated 44 of them as covered by a general licence for companies winding down operations in Russia. It also found that the reporting requirements for payments made under that licence had not been met, “considered an aggravating factor” and “an offence in its own right”.
- Expiry. The same notice records that Colorcon “continued to make payments after the expiry” of the licence. A wind-down licence is a bridge with an end, and OFSI counted the payments outside its dates as breaches: £128,277.72 of the £191,290.57 paid in total.
Where a licence appears in other cases
The Svarog notice shows a licence as an investigative thread. OFSI had issued a general licence in March 2022 to allow the orderly wind-down of positions involving Sovcomflot, and it became relevant to a much larger investigation when OFSI learned that Svarog had transacted with a Sovcomflot subsidiary. That case ended in a £5,000 penalty for failing to answer OFSI’s request for information, not for the underlying dealings. The licence was how the question arose.
The Herbert Smith Freehills Moscow penalty involved an audit-fee overdraft, insurance and a redundancy payment, paid to designated banks while an office closed. It is not a licence case. It belongs here because it shows the kind of routine payment a wind-down produces, which a screening process built around counterparties rather than around the accounts they use can miss.
What this means for detection
For an investigator, a claimed general licence is a checkable fact. Which licence, on what date, under what conditions, and whether the reporting was done. For a bank or exporter, the useful question is whether a counterparty’s reliance on a licence has a record behind it. The page on professional enablers describes what the absence of one looks like from the side of the firms that advise on it.