Attached is the link to OFSI blog, where OFSI clarify how they will assess “reasonableness” of (1) legal fees; and (2) costs related to the maintenance of complex frozen assets (e.g., villas, yachts, private jets, etc.).
The reasonableness of such fees and costs is a pre-condition for OFSI to grant individual licences which authorise their payment. In essence, independent reports confirming that the fees/costs are reasonable are required to justify reasonable, provided that certain thresholds are exceeded and/or the costs are otherwise material or non-standard.