Call for evidence on ownership and control in financial sanctions regulations

OFSI has extended the deadline for its call for evidence on how UK financial sanctions regulations on ownership and control are applied in practice. The call for evidence will now close at 11:59pm on Monday 20th April 2026.

We have extended the deadline to allow firms and other stakeholders more time to prepare and submit evidence, including practical examples from real cases. 

The Call for Evidence seeks industry views on how the ownership and control test is applied in practice, including where firms face challenges. The test is designed to stop designated persons from sidestepping UK sanctions by hiding behind complex company structures, trusts or proxies. However, 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.

We are particularly interested in evidence and examples on:

• 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.  

Read the full call for evidence and how to respond here.   

Read more about the background and scope of the exercise in our blog here.