Guidance

Licensing Delegation Framework for Counter Terrorism

Updated 2 February 2026

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This publication is available at https://www.gov.uk/government/publications/financial-sanctions-licensing/licensing-delegation-framework-counter-terrorism-branch

The Delegation Framework (“DF”) outlines where licensing decision making under the UK’s Counter Terrorism sanctions regimes should sit. Under this framework decisions can be taken at four different levels dependent on their nature and legal/ policy risk.

Ministerial approval is required for cases considered contentious by default including:

  • Applications for new licences.

  • Amendments which involve a significant change to the DP’s authorisations or obligations in respect of those authorisations under the Counter Terrorism (“CT”) regimes.

For all other decisions Ministers have delegated authority to OFSI Civil Servants at the following levels:

OFSI SCS will approve any cases for:

  • A one-off medium risk activity – situations sometimes arise that require licences which are relatively uncontroversial in nature, which are consistent with previous Ministerial decisions

  • A significant change to the DP’s authorisations

OFSI’s Head of Intelligence and Counter Terrorism (G6) and/or Head of Counter Terrorism (G7) can approve the following licence applications:

  • Access to state benefits from Government agencies such as DWP;

  • Repayment of over -payments, fees, refunds etc. from previously licenced sources;

  • One-off low risk activity – situations sometimes arise that require licences which are uncontroversial in nature, which are consistent with previous Ministerial decisions;

  • Corrections to licences arising from typographical errors;

  • Administrative amendments: for example, minor changes to update bank details for approved suppliers or the DP’s account; or

  • Amendments where no additional funds are made available to the DP and where their licensing permissions remain the same e.g. only an extension to the licence period is required.

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