General license (sanctions)
An authorization published by the sanctions authority that lets anyone carry out an otherwise prohibited transaction, as opposed to a specific license granted to one applicant.
A general license is an authorization published by the sanctions authority, OFAC in the United States or OFSI in the United Kingdom, that lets anyone meeting its conditions carry out a transaction the program prohibits. It serves to allow an orderly wind-down, to protect humanitarian aid or to avoid a shock to an essential market. A specific license, by contrast, is applied for case by case, takes weeks or months, and covers its holder alone. For insurance, the distinction is concrete: an indemnity owed to a person who has become sanctioned can be paid only under the shelter of a license, and a general license almost always has an end date. An underwriter who keeps a risk exposed to a sanctions program must therefore know, for each possible payment, which license it would travel under and until when.
On February 24, 2022, the day Ukraine was invaded, OFAC issued General License 8, authorizing until June 24, 2022 energy-related transactions with several Russian banks it had just sanctioned, so that oil and gas payments would not stop overnight.
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