OFSI Addresses 'Reasonableness in Licensing'
The United Kingdom's Office of Financial Sanctions Implementation in a June 30 blog post sought to clarify the term “reasonableness in licensing.” When deciding to unfreeze funds subject to sanctions for the payment of professional fees and expenses for legal services, OFSI must consider that those fees are “reasonable.”
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The post laid out several criteria to consider when applying for a legal fees and expenses licenses, including whether the work already occurred, what the work will entail, which fee earners will be involved, the fee earner's hourly rate, how many hours each fee earner will be estimated to spend and expected expenses. Filing parties should also explain why the proposed activity is necessary and consider obtaining quotes from more than one supplier to ensure a reasonable rate. If such a quote is unavailable, an “evidence-based estimate” will do, the post said.