Sanctions Evasion Reference

General licence

A published authorisation permitting a defined category of otherwise prohibited transactions, available to anyone who meets its terms without applying.

also known as

GL

reviewed

2026-08-20

General licences carve out humanitarian trade, wind-down periods, telecommunications, certain legal services and similar categories. Because they are self-executing, reading their exact scope matters: they authorise what they say and nothing adjacent.

In evasion terms they define the shape of the space to be exploited. Overstating the reach of a general licence, or continuing to rely on one after its wind-down period has expired, is a recurring feature of penalty notices.

Where this term is used

  • How is correspondent banking used to evade sanctions? — Using a chain of banks that each know only their own customer, so that a payment for a restricted party reaches a currency it could not access directly, without any bank in the chain seeing the whole transaction.
  • What is a professional enabler? — A lawyer, accountant, formation agent or broker whose services are what makes a concealment structure work, and whose repeated involvement across unconnected clients is itself the evidence.
  • What is third-country transshipment? — Routing restricted goods through an intermediate country so that the shipment reaching the restricted destination appears to originate somewhere the exporter would have supplied without question.

Related terms

  • Specific licence — A written authorisation issued to a named applicant permitting a particular transaction that would otherwise be prohibited.
  • Blocking — Freezing property and interests in property of a designated person that come within a jurisdiction, so it cannot be transferred, paid, withdrawn or otherwise dealt in.
  • Sanctions — Restrictions imposed by a state or international body on dealings with a named person, entity, sector or country, enforced against anyone within that authority's jurisdiction.

Sources

  1. Frequently Asked Questions. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.
  2. Sanctions Programs and Country Information. U.S. Department of the Treasury, Office of Foreign Assets Control, 2026.

All glossary terms