Alexander Zalivako

2026.07.21 – UK OFSI – Basic Needs Allowance FAQs

Below are the FAQs and the link.

Basic Needs Allowance

197. What is a basic needs allowance licence?

A Basic Needs Allowance (BNA) licence is a type of specific licence which OFSI may issue under the basic needs licensing ground across all non-counter-terrorism sanctions regimes. It permits a designated person (DP) to access a capped monthly sum from their otherwise frozen funds to meet essential day-to-day living expenses. OFSI benchmarks the allowance to reflect a median income household rather than the DP’s previous lifestyle or claimed expenditure.  Rent or mortgage payments are considered separately from the BNA and assessed on a case-by-case basis.

Added on: 21 Jul 2026

198. What is the purpose of the basic needs allowance?

The basic needs allowance is intended to help ensure that a DP and any financially dependent family members can meet their day-to-day living costs, broadly in line with a median-income household. It is not intended to enable a DP to maintain the lifestyle, wealth, or business activities they enjoyed prior to designation.

DPs applying for or operating under a BNA licence should ensure that expenditure remains consistent with this purpose. Any party facilitating payments under a BNA licence should similarly satisfy itself that the payments fall within the terms and purpose of the licence.

Added on: 21 Jul 2026

199. Do basic needs allowance licences include reporting requirements?

Yes. Basic needs allowance licences include reporting conditions requiring expenditure to be evidenced and reported to OFSI. This is a proportionate method that enables OFSI to maintain oversight of the usage of the licence and may inform any future decision when licences are renewed or varied.

Applicants should be prepared to comply with any reporting requirements imposed as conditions of a licence. Compliance with those conditions does not guarantee that a licence will be renewed or varied.

Added on: 21 Jul 2026

200. What can the basic needs allowance be spent on?

OFSI does not provide an exhaustive list of approved purchases. A DP has broad discretion, though not total, in how the allowance is used. That discretion is limited by the terms of the licence, the relevant sanctions regulations, and the purpose for which the licence is granted

The allowance is intended to cover goods and services that reasonably constitute basic needs. This may include (but is not limited to) food, clothing, personal hygiene, local transport, basic household items, and hairdressers. It does not cover expenditure that falls outside the terms of the basic needs licencing purpose, nor expenditure which would otherwise breach the financial sanction’s regime.  

Some discretionary spending may be consistent with the terms of a BNA where it supports basic family life and remains proportionate to the benchmark of a median-income household. This may include recreation, education, leisure, and other miscellaneous goods and services. Whether such expenditure is appropriate will depend on the circumstances and must remain consistent with the purpose of the licence.

Added on: 21 Jul 2026

201. Does the basic needs allowance licence permit carry-over of any monthly underspend?

No. Each month’s allowance is a fixed, standalone cap. If a DP does not use the full allowance in a given month, the unspent amount cannot be carried forward or added to the following month’s allowance. The monthly cap resets at the start of each new month.

Added on: 21 Jul 2026

202. Does OFSI license costs separately that may fall outside of the core basic needs allowance?

Yes. Where a cost cannot reasonably be met from the basic needs allowance, OFSI may consider a separate licence application. Such applications are assessed on their individual merits and approval is not automatic.

 OFSI will consider whether the relevant cost could reasonably be met from within the basic needs allowance. In particular, OFSI will assess whether the expenditure is of a type that a median-income household would ordinarily absorb through routine day-to-day spending.

Where a cost could reasonably be met from the basic needs allowance, OFSI would generally expect it to be funded from that allowance rather than licensed separately.

Applicants seeking separate licensing should therefore explain why the expenditure cannot reasonably be met from the basic needs allowance, how the relevant licensing purpose is met, and provide supporting evidence where appropriate. Applications can be submitted via OFSI’s application form at: OFSI launches online forms for reporting and licences – Office of Financial Sanctions Implementation.

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