Context
The OFSI has launched a call for evidence to seek industry’s views on how UK financial sanctions regulations on ownership and control are applied in practice, including how firms implement the regulations and where they face challenges.
Key points to note and next actions
The ownership and control test is designed to stop sanctioned individuals and entities from sidestepping UK sanctions by hiding behind complex company structures, trusts or proxies. However, industry representatives report to OFSI that assessing the ability of a designated person to control an entity – even if they are not actively doing so – can be difficult in practice and may create additional costs and legal risk. OFSI is therefore asking firms, representative bodies and other interested stakeholders to share evidence and practical examples of:
- How often ‘hypothetical control’ is present in real financial sanctions cases;
- The impact it has on compliance costs, legal risk and business decisions (including derisking);
- Whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations.
This information will help OFSI understand whether the current approach is as clear, effective and proportionate as it should be, so that sanctions remain tough on those they target while being workable for legitimate businesses.
The Call for Evidence is open until 13 April 2026.