Notice regarding update to UK Office of Financial Sanctions Implementation (“OFSI”) General Licence INT/2025/6641960 (the “Brokerage Accounts GL”)

As detailed in our communications to Sova Capital Limited’s (in special administration) (“Sova”) clients on 1 August 2025, OFSI published the Brokerage Accounts GL on 18 July 2025 with an expiry date of 16 July 2026. Please note that on 13 July 2026, OFSI extended the expiry date of the Brokerage Accounts GL to 16 July 2027.

Since the publication of the Brokerage Accounts GL by OFSI on 18 July 2025, the Joint Special Administrators of Sova have engaged in extensive correspondence with clients whose client assets potentially may have been impacted by the Brokerage Accounts GL.

As explained in that correspondence, the Brokerage Accounts GL may allow “non-designated persons who have made investments through designated brokers to transfer their funds to a non-designated broker”.  However, this is subject to various terms and conditions. They significantly limit the operation of the Brokerage Accounts GL to the specific client assets Sova holds. The large majority of client assets fall outside of the Brokerage Accounts GL.

These limitations include the following:

• The Brokerage Accounts GL only concerns specific UK sanctions restrictions against Russia. Importantly, it does not authorise activities, including transfers of client assets, prohibited under EU and/or US sanctions (where these also apply). Any such transfer that would involve an EU or US sanctions jurisdictional nexus therefore cannot be carried out without obtaining additional licences in all relevant jurisdictions. Sova cannot transfer these assets.
• The Brokerage Accounts GL does not apply where Sova’s clients’ underlying clients are subject to a UK asset freeze.
• Consent must be obtained from various other relevant stakeholders prior to proceeding. Sova cannot transfer any assets without these consents.
• Client asset transfers involve various other parties (not just Sova). Those other parties must also agree to rely on the Brokerage Accounts GL. Sova and the Joint Special Administrators have no control over the actions of these parties and cannot guarantee that they will perform their activities, even if authorised.

Whilst the extension of the GL deadline provides additional time for clients to engage with the Joint Special Administrators in order to consider whether any potential transfers may be pursued in reliance on the Brokerage Accounts GL, it does not resolve the above limitations, which continue to apply.

Further information has been provided to Sova’s potentially affected clients. If you are a customer of a broker which dealt with Sova, please contact your broker directly for more information about the Brokerage Accounts GL.