Category: OFSI (UK)

  • Today, OFSI published the following blog post about how it prioritizes licensing applications:

    How OFSI Prioritises Licence Applications

    OFSI remains committed to a transparent, fair and effective licensing process. Publishing this prioritisation framework is part of our continuing efforts to ensure that applicants understand how we assess cases and what they can do to support timely decision‑making.  

    OFSI receives a wide variety of licence applications each year, ranging from urgent humanitarian requests to complex commercial transactions. In the financial year 2024-2025, OFSI took over 900 licensing decisions. It is not possible to deal with all applications as soon as they are received. Publishing our prioritisation framework aims to help applicants understand how OFSI manages competing demands and how applications are prioritised.  

    Each licence application is assessed against seven criteria as set out below. These criteria help caseworkers understand urgency, risk, stakeholder impact and possible harm caused by delay. Applications are then categorised as high, medium or low priority. 

    While the framework provides structure, OFSI caseworkers continue to use professional judgement and may adjust prioritisation where circumstances require a different approach. Additionally, even if a licence application is prioritised as urgent, complexities may mean it still takes time to complete. Applicants should therefore submit licence applications well in advance of when they are needed, wherever possible. 

    The Criteria 

    1. Nature of the licensing purpose  

    Humanitarian applications, basic needs, or anything where delay could significantly affect access to justice (i.e. where there are court dates which must be complied with) are generally treated as high priority.  

    Generally, you won’t be prohibited from providing legal advice under an asset freeze. However, the payment for legal services and the provision of legal services on credit do require an OFSI licence. On that basis, applications may not immediately be considered as a high priority. OFSI has issued a Legal Services General Licence to allow payments for legal fees within certain limits and under certain conditions. It is recommended that you consult the Legal Services General Licence prior to an application to OFSI to determine whether that General Licence would be applicable to you. 

    2. Materiality to the applicant or affected parties 

    OFSI assesses how significant the application is in real terms. This includes the applicant’s circumstances, the size of the transaction relative to their means, and whether delay would result in economic loss. 

    3. Timing considerations 

    Applications may be prioritised where a decision is genuinely time‑sensitive, where delays would cause harm, or where the application has already been outstanding for a significant period. 

    4. UK economic impact 

    Applications that may affect UK jobs, business continuity or wider economic welfare may be prioritised. 

    5. Administrative impact on OFSI 

    Some cases may affect OFSI’s ability to progress other applications — for example, those forming part of a series of related applications. 

    6. Reputational or strategic impact 

    Applications may be prioritised where delay could undermine confidence in the UK sanctions regime, affect relationships with key partners, or have significant implications for foreign policy, national security or energy security. 

    7. Complexity of the application 

    Complex or precedent‑setting cases may require more time and scrutiny. These may be prioritised to ensure consistent and robust decision-making. However, even when a case is prioritised in accordance with this criterion, an application may still take time to complete. 

    How the criteria work in practice 

    High‑priority cases generally meet at least two of the criteria at a high level -humanitarian cases, or cases where a risk to life has been demonstrated, are almost always classified as high priority. Medium‑priority cases demonstrate a moderate level of impact across several criteria. Low‑priority applications generally show limited impact in most areas. 

    Caseworkers may adjust priority where individual circumstances justify doing so. 

    These criteria only assist in the prioritisation of applications and do not create an automatic right to priority or expediency. The outcome of this assessment does not affect the outcome of the application and there may still be a number of applications which have been categorised with the same urgency.  

    How applicants can support the process 

    Applicants can help OFSI process their applications more efficiently by submitting clear, complete and well‑evidenced information. Here are some steps that will help: 

    • Provide a clear legal basis 

    Applicants should set out the specific licensing ground that applies and explain  how their circumstances meet it. 

    • Include all required information upfront 

    Missing or unclear information is one of the most common causes of delay. Applicants should provide evidence of urgency, where applicable, to assist in the prioritisation of applications. 

    • Avoid repeat or speculative applications 

    Submitting an application again without new information, or submitting entirely speculative applications “just in case”, may delay processing and is unlikely to result in the case being prioritised as high priority. You may wish to seek legal advice in advance of making an application and check whether any General Licences apply to your situation.  

    • Highlight genuine deadlines 

    Where a deadline exists—such as a court date or risk of hardship—applicants should clearly explain and evidence this in their application. 

    • Use OFSI’s online application form 

    Using OFSI’s online application form will ensure that cases are received by the correct team as early as possible and could prevent any additional delays 

    OFSI is unable to provide legal advice to applicants and if you are in any doubt, you should seek independent legal advice in relation to the matters raised. You may also wish to consult OFSI’s other guidance products, such as: 

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  • Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence INT/2025/8031092 amended and 1 FAQ amended

    On 25 February 2026, the General Licence INT/2025/8031092 was amended, the expiry date was extended to 25 August 2026.

    Any persons intending to use General Licence INT/2025/8031092 should consult the copy of the Licence for full details of the permissions and usage requirements.

    FAQ 174 was also amended to reflect the amendment of the general licence.

    The General License:

    The FAQ:

    174.Can business operations with Lukoil International GmbH continue as normal with regard to UK financial sanctions?

    On 15 October 2025, the UK designated PJSC Oil Company Lukoil (“Lukoil”) under the Russia (Sanctions) (EU Exit) Regulations 2019 (“the Russia Regulations”). Lukoil is consequently subject to financial sanctions, as are entities owned or controlled by Lukoil.

    OFSI notes the ongoing negotiations on the sale of PJSC Lukoil’s international assets.

    In that context, on 27 November 2025 OFSI issued General Licence INT/2025/8031092. This GL permits the continuation of business with respect to Lukoil International GmbH (“Lukoil International”) which is a subsidiary of PJSC Lukoil and subsidiaries of Lukoil International.

    Users of General Licence INT/2025/8031092 should carefully consider all relevant conditions, in particular those relating to payments made to Lukoil International and/ or Lukoil International subsidiaries.

    In line with OFSI licensing practice the expiry date of General Licence INT/2025/8031092 is set out in the amended licence document. Any renewal of General Licence INT/2025/8031092 would be considered in the context of the ongoing negotiations on the sale of PJSC Lukoil’s international assets.

    HM Treasury may vary, revoke or suspend General Licence INT/2025/8031092 at any time.

    Amended on: 25 Feb 2026

  • OSFI’s additions:

    And the UN Press Release:

    Security Council 1591 Sanctions Committee Adds Four Entries to Its Sanctions List

    On 24 February 2026, the Security Council Committee established pursuant to resolution 1591 (2005) concerning the Sudan approved the addition of the entries specified below to its Sanctions List of individuals and entities subject to the measures imposed by the Security Council and adopted under Chapter VII of the Charter of the United Nations.

    A. Individuals

    SDi.007 Name: 1: GEDO 2: HAMDAN 3: AHMED Title: NA Designation: Commander for the North Darfur section of the Rapid Support Forces  DOB: NA POB: NA Good quality a.k.a.: Abu Nashuk  Low quality a.k.a.: NA Nationality: Sudan Passport no: NA National identification no: NA Address: NA Listed on: 24 Feb. 2026 Other information: Gender: Male

    SDi.008 Name: 1: ABDUL 2: RAHIM 3: HAMDAN 4: DAGALO Title: NA Designation: Rapid Support Forces (RSF) Deputy Leader DOB: 1 Jan. 1972 POB: Khartoum, Sudan Good quality a.k.a.: NA Low quality a.k.a.: NA Nationality: Sudan Passport no: NA National identification no: NA Address: NA Listed on: 24 Feb. 2026 Other information: Gender: Male

    INTERPOL-UN Security Council Special Notice web link:  https://www.interpol.int/en/How-we-work/Notices/View-UN-Notices-Individuals

    SDi.009 Name: 1: AL-FATEH 2: ABDULLAH 3: IDRIS Title: NA Designation: Brigadier General of Rapid Support Forces DOB: NA POB: NA Good quality a.k.a.: Abu Lulu  Low quality a.k.a.: NA Nationality:Sudan Passport no: NA National identification no: NA Address: NA Listed on: 24 Feb. 2026 Other information: Gender: Male

    SDi.010 Name: 1: TIJANI 2: IBRAHIM 3: MOUSSA 4: MOHAMED Title: NA Designation: Field Commander of the Rapid Support Forces DOB: NA POB: NA Good quality a.k.a.: Al Zeir Salem  Low quality a.k.a.: NA Nationality: Sudan Passport no: NA National identification no: NA Address: NAListed on: 24 Feb. 2026 Other information: Gender: Male

    The Committee has made accessible on its website the narrative summary of reasons for listing of the above entry, at the following URL:  https://main.un.org/securitycouncil/en/sanctions/1591/materials/summaries.

    Press releases concerning changes to the Committee’s Sanctions List may be found in the “Press Releases” section on the Committee’s website at the following URL:  https://main.un.org/securitycouncil/en/sanctions/1591/press-releases.

    The updated version of the Committee’s Sanctions List, available in HTML, PDF and XML format, may be found at the following URL:  https://main.un.org/securitycouncil/en/sanctions/1591/materials.

    The United Nations Security Council Consolidated List is also updated following all changes made to the Committee’s Sanctions List and is accessible at the following URL:  https://main.un.org/securitycouncil/en/content/un-sc-consolidated-list.

  • From OFSI’s blog:

    Sanctions compliance in practice: lessons from OFSI’s £160,000 Bank of Scotland penalty

    OFSI, 23 February 2026 – OFSI Blog

    In January 2026, OFSI published the details of an £160,000 monetary penalty imposed on Bank of Scotland Plc, a subsidiary of the Lloyds Banking Group, for breaching the Russia financial sanctions regime. 

    The lessons in this case go beyond one bank and one customer. OFSI’s published outcomes demonstrate how OFSI assesses breaches, the circumstances surrounding them, and how weaknesses in screening, escalation and training are taken into account when breaches have occurred. These lessons can help firms better understand how to run sanctions controls in practice, and how weaknesses in screening, escalation and training can expose firms to the risk of breaching.

    UK financial sanctions apply to any conduct in the UK and to all UK persons (including UK legal entities) anywhere in the world.

    Lesson 1: Screening data and configuration really matter

    OFSI strongly encourages firms to utilise all information available to them to optimise sanctions controls relative to their risk. Firms are advised to assess and employ appropriate resources to enhance the effectiveness of such systems.

    In this case, Lloyds Banking Group had taken measures to implement sanctions screening. However, its automated sanctions systems failed to detect a spelling variation of a designated individual’s name.

    What this means for you:

    • Ask whether your screening can cope with spelling and transliteration variants.
    • Where your risk justifies it, consider enriched screening and commercial list providers alongside the new UK Sanctions List.

    Lesson 2: Automation is not a safety net

    This case illustrates that there are inherent risks associated with automated sanctions screening. It is essential that firms establish robust and explicit contingency procedures.

    Internal policies should provide robust and explicit guidance to staff regarding the escalation of potential sanctions concerns. This is particularly pertinent for areas of business that are more exposed to sanctions risk, such as those involving Politically Exposed Persons (PEPs).

    What this means for you:

    • Make sure front‑line teams know when to escalate, who to contact and how – not just that they “should escalate”.

    Lesson 3: Training must match today’s sanctions landscape

    The sanctions landscape has evolved significantly since the Russian invasion of Ukraine in February 2022, and continues to develop with ever-shifting geopolitical events. It is imperative that all training and associated materials relating to sanctions are regularly reviewed and updated.

    What this means for you:

    • Training content must be regularly reviewed and updated to accurately reflect relevant regulatory and geographical developments to ensure continued compliance.

    Lesson 4: Voluntary disclosure can shape the outcome

    This case is an example of prompt, voluntary disclosure of a potential breach. Lloyds Banking Group, on behalf of Bank of Scotland, made an initial notification within two weeks of identifying a potential breach. OFSI seeks to reward prompt and complete voluntary disclosures through penalty discounts, which alongside co-operation can result in a discount of up to 30% under new guidance.

    What this means for you:

    • You should report suspected breaches to OFSI as soon as practicable.
    • Where full disclosure is not possible, a person should make an early disclosure with partial information on the basis that they are still working out the facts and will make a further and full disclosure as soon as possible.
    • Reporting breaches protects the integrity of financial sanctions and assists government and law enforcement agencies in tackling serious crime.

    What firms should do next

    This case shows that OFSI is focused not only on whether firms have sanctions controls, but on how effectively those controls operate in practice. From the way screening data is configured, to how concerns are escalated, how often training is refreshed, and how quickly potential breaches are reported.

    Firms with UK touchpoints, including those operating internationally, should:

    • review their sanctions screening, escalation procedures and training considering these lessons
    • ensure they understand and comply with their reporting obligations, including reporting “as soon as practicable” where required.

    You can read the full penalty notice here: https://www.gov.uk/government/publications/imposition-of-monetary-penalty-bank-of-scotland-plc

    Further information and guidance on reporting information to OFSI is available here: https://www.gov.uk/government/organisations/office-of-financial-sanctions-implementation

  • Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence INT/2024/4761108 amended

    On 23 February 2026, the General Licence INT/2024/4761108 was amended to:

    • Amend the definition of “Person”.
    • Include the definition of “Individual”, “Entity”, “UK Bank Account”, “Non-UK Bank Account” and “UK DP”.
    • Include a new separate permission that allows an Entity to make use of the retail banking services of a designated Credit or Financial Institution to make or receive a payment of for the personal use of an individual, provided the account at the final institution in the chain of payments to which the payment is processed is a UK Bank Account or a Non-UK Bank Account.
    • For the avoidance of doubt, the intended payments under this new permission remain exclusively for personal purposes and do not include payments for business or commercial activities. Possible examples of permitted payments include, but are not limited to, payments from or to entities for tuition fees, accommodation costs, pension, or living expenses.
    • No payment is permitted under this General Licence if the payment relates to the provision of goods or services for commercial purposes.
    • Increase the cumulative limit of permitted payments from £50,000 to £55,000.
    • Extend the expiry date of the licence to 23:59 on 23 February 2028.
    • The reporting requirements have been amended.

    Any persons intending to use General Licence INT/2024/4761108 should consult the copy of the Licence for full details of the permissions and usage requirements.

    The amended General Licence:

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  • Office of Financial Sanctions Implementation HM Treasury

    OFSI General Licence INT/2026/8893924 and OFSI General Licence INT/2026/8889196 issued and OFSI General Licence INT/2025/5635700 amended

    On 24 February 2026, the General Licence INT/2026/8893924, Maritime Mutual Re-Insurance Wind Down was issued. The General Licence allows for the winding down of insurance policies written by Maritime Mutual entities and their subsidiaries before their designation. 

    Any persons intending to use General Licence INT/2026/8893924 should consult the copy of the Licence for full details of the definition, permissions, and usage requirements.

    The General Licence:

    On 24 February 2026, the General Licence INT/2026/8889196, PJSC Transneft Wind Down was issued. The General Licence allows for Persons to wind down from any transactions involving the DP to which that Person is a party.

    Any persons intending to use General Licence INT/2026/8889196 should consult the copy of the Licence for full details of the definition, permissions, and usage requirements.

    The General Licence:

    On 24 February 2026, the General Licence INT/2025/5635700, Russian Oil Exempt Projects was amended to include any entity owned or controlled, directly or indirectly, by PJSC Transneft, following their designation by the UK. Additionally, Schedule 1 of the General Licence was amended to add the Druzhba Pipeline.

    Any persons intending to use General Licence INT/2025/5635700 should consult the copy of the Licence for full details of the definition, permissions, and usage requirements

    The amended General Licence:

  • The press release:

    UK announces biggest sanctions package against Russia four years on from full-scale invasion of Ukraine

    The UK has announced a landmark sanctions package, cutting off critical oil revenues and further degrading the Kremlin’s ability to wage its illegal war. 

    From: Foreign, Commonwealth & Development Office and The Rt Hon Yvette Cooper MP

    Published. 24 February 2026

    • Nearly 300 new sanctions announced as UK cracks down on critical Russian energy revenues, including oil exports, and key suppliers of military equipment fuelling war efforts.   
    • Russian Oil revenues are now at their lowest since 2020 as the UK and international partners continue to ratchet up pressure on Putin’s flailing war machine. 
    • News comes as the Foreign Secretary is in Kyiv announcing new support for Ukrainian resilience.

    The package, the largest since the early months of the invasion in 2022, comes four years on from Putin’s barbaric full-scale invasion of Ukraine.

    Today’s action targets one of the world’s largest oil pipeline companies, PJSC Transneft, responsible for transporting over 80% of Russian oil exports, further hampering the Kremlin’s desperate scramble to find buyers for its sanctioned oil. 

    So far international sanctions have deprived Putin of over $450 billion – the equivalent of two more years of funding for his illegal war. Since this time last year, Russia’s economy has stagnated and their revenue streams have been in freefall, with oil revenues at their lowest since 2020. Scrambling to make up for lost revenues, the Kremlin has been forced to hike taxes for ordinary Russians, including VAT and corporation tax. 

    New measures also hit Russia’s dark web of illicit oil traders, sanctioning 175 companies in the ‘2Rivers’ oil network, one of the largest shadow fleet operators globally and a major trader of Russian crude oil.

    Deterring, disrupting and degrading the Russian shadow fleet remains a priority for this government, and this latest swathe of sanctions includes 48 oil tankers transporting oil as part of the Kremlin’s desperate attempt to soften the blow of crushing sanctions. To the Kremlin and those seeking to profit from this illicit trade, the message is clear – Russian oil is off the market.

    The UK has now sanctioned over 3,000 individuals, businesses and ships under its Russia regime. The Foreign Secretary is visiting Kyiv today where she has also announced a new package of military, humanitarian and reconstruction support for Ukraine.

    Foreign Secretary Yvette Cooper said: 

    Russia is now four years into what Putin believed would be a three-day invasion. As the Kremlin continues its barbaric assault against innocent civilians that have suffered their most brutal winter in a decade, the courage and determination of the Ukrainian people endures. 

    The UK has today taken decisive action to disrupt the critical financing, military equipment and revenue streams that sustain Russia’s aggression, in our largest raft of measures since the early months of the invasion. 

    Today I’m in Kyiv announcing £30 million in funding to strengthen Ukrainian energy resilience and support recovery, taking the total UK support to £21.8 billion since the start of the war. 

    We will continue to stand with the people of Ukraine and defend European security - Ukraine’s security is our security.

    UK sanctions are ramping up the pressure on Putin’s economy and war machine. Putin’s war economy is faltering, and its revenues are in freefall. 

    Today’s action also clamps down on: 

    • 49 entities and individuals involved in sustaining Russia’s war machine, including international suppliers that are providing the vital goods, components and technology in Russian drones and other weapons terrorising innocent Ukrainian civilians.  
    • 3 civil nuclear energy companies and 2 individuals involved in trying to secure contracts for new Russian nuclear installations overseas, opening up additional energy revenue streams to make up for plummeting oil revenues.
    • 6 targets in Russia’s beleaguered Liquified Natural Gas (LNG) industry including ships, traders and Russia’s Portovaya and Vysotsk terminals responsible for exporting Russian LNG. 
    • 9 Russian banks which process cross-border payments vital to Russia’s attempts to cling on to access to international markets and help finance the Kremlin’s war effort. 

    Today the UK has also announced over £30 million to strengthen Ukrainian resilience after a brutal winter of Russian strikes plunging civilians into freezing darkness. Over £25 million will deliver repairs to damaged energy infrastructure, and support the men, women and children whose lives continue to be uprooted by Russia’s aggression. A further £5 million is helping to drive justice and accountability for victims of alleged Russian war crimes.  

    As the world marks this grim milestone, the UK is advocating for our Ukrainian allies on the world stage, with Minister for Europe Stephen Doughty rallying partners around the push for a just and lasting peace at the UN Security Council in New York.  

    Every missile and drone that strikes Ukraine only strengthens our resolve. Putin thinks that he can outlast the UK and our allies, he is sorely mistaken.  

    Notes to editors

    • The information in this press release was correct on the date of publication. View the UK Sanctions List for the current list of those subject to sanctions. 
    • Please see here for a full list of today’s targets.

    Media enquiries

    Email newsdesk@fcdo.gov.uk

    Telephone 020 7008 3100

    Email the FCDO Newsdesk (monitored 24 hours a day) in the first instance, and we will respond as soon as possible.

    And the update:

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  • Office of Financial Sanctions Implementation HM Treasury

    OFSI Webinar: Civil Enforcement Processes – Updated Guidance

    Dear all,

    OFSI is pleased to invite you to our webinar on Tuesday 3 March, 14:00-15:00, covering the recently published consultation response on improving civil enforcement processes for financial sanctions. Feedback from this consultation has informed a strengthened enforcement framework, and OFSI updated its guidance on 9 February 2026 to reflect these enhancements. The guidance can be found here.

    This session will provide an opportunity to walk through the key changes in OFSI’s enforcement and monetary penalties guidance and highlight important points for industry. The webinar is designed to support understanding of the updates and their implementation.

    To register, please click here

    If you have any questions about the webinar or would like to submit a question in advance, please contact the OFSI Enforcement Consultation Team at ofsienforcementconsultation@hmtreasury.gov.uk. Pre‑submitted questions should be sent by close of play 24 February.

    Kind regards,

    OFSI Enforcement Consultation Team

  • Office of Financial Sanctions Implementation HM Treasury

    Call for evidence on ownership and control in financial sanctions regulations

    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.   

    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. 

    We are 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 us 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 13th April 2026. 

    The Call for Evidence page:

    Open call for evidence

    Ownership and Control Test in UK Financial Sanctions Regulations

    From: Office of Financial Sanctions Implementation

    Published 16 February 2026

    Summary

    Ownership and Control Test in UK Financial Sanctions Regulations

    This call for evidence is being held on another website.

    This call for evidence closes at

    Call for evidence description

    HMG is launching 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.   

    We are 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 de-risking); 
    • Whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations.  

    This information will help us 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. 

    How to respond

    OFSI is keen to hear from a wide range of stakeholders in response to the consultation, including businesses, financial institutions, legal and compliance professionals, civil society and other interested parties.  

    This Call for Evidence goes live on Monday 16th February 2026 and will be open for eight weeks. Responses will be accepted until 11:59pm on Monday 13th April 2026. 

    Responses are encouraged via the online form.

    If you cannot respond via the online form, you may send your response by email to oc-callforevidence@hmtreasury.gov.uk 

    Please state whether you are responding as an individual or representing the views of an organisation, business, or representative body.

    Privacy notice

    Click here to view the privacy notice for the call for evidence, which sets out how HM Treasury will use your personal data and explains your rights under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA).

    The Call for Evidence PDF:

    There’s an HTML page, too.

    Finally, OFSI wrote a blog post:

    Call for evidence on ownership and control in financial sanctions regulations

    OFSI, 16 February 2026 – OFSI Blog

    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.   

    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 (DP) 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. 

    This information will help us 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. 

    Background  

    The policy intention of the UK government’s approach to ownership and control (O&C) in UK sanctions regulations is to ensure that sanctions cannot be easily circumvented. The two-condition O&C test set out in legislation (e.g. Regulation 7(4) of The Russia (Sanctions) (EU Exit) Regulations 2019) serves as a critical safeguard against sanctions circumvention, by ensuring that entities owned or controlled by a DP are subject to financial sanctions, even if not explicitly named on the UK Sanctions List. In particular, the second condition of that test (also referred to as ‘the control test’) is broadly drafted to capture as much activity as possible. 

     We have repeatedly heard from financial and legal representatives that they face challenges when implementing O&C provisions, with particular emphasis on the degree of uncertainty of the control test and the potential for multiple and sometimes conflicting interpretations. Firms have told OFSI that determining when these situations constitute control for sanctions purposes can be challenging and that it is not always clear what evidence should be reasonably sought to support these assessments. 

    In response to industry feedback, HM Government committed to delivering measures to provide further clarity on ownership and control as part of the Review of Sanctions Implementation and Enforcement, published in May 2025. We are therefore launching a call for evidence on how the UK’s O&C test is applied during financial sanctions compliance. We want to hear from those who apply the test about where it works well, where challenges arise and the practical impacts of these assessments. Formal evidence across these areas, in addition to anecdotal evidence already held by OFSI, will help form a comprehensive picture of how implementation works in practice.  

    The call for evidence focuses on control as a direct response to industry feedback, which has highlighted greater implementation challenges associated with the control element of the O&C test rather than the ownership element. On ownership, HMG continues to actively explore options to respond to calls for greater alignment with international partners, including adopting an aggregation model and amending the 50% ownership rule to “50% or more,” in line with the EU and US sanctions frameworks.   

    Why we are calling for evidence 

    Under UK financial sanctions, a DP is subject to an asset freeze. The regulations also apply to entities that designated persons own or control.  

    An entity is owned or controlled directly or indirectly by another person in any of the following circumstances:  

    • The person holds more than 50% of the shares or voting rights in an entity.  
    • The person has the right to appoint or remove a majority of the board of directors of the entity.  
    • It is reasonable, having regard to all the circumstances, to expect that a DP would (if  they chose to) be able, in most cases or significant respects, by whatever means and whether directly or indirectly, to achieve the result that affairs of an entity are conducted in accordance with that DP’s wishes.   

    Evidence presented that the DP has not exercised control does not mean they do not have the ability to do so and therefore does not necessarily refute a DP’s control over an entity. This may be referred to as a DP’s hypothetical ability to exercise control, or simply ‘hypothetical control.’  If a DP can continue to move money or operate through others, the impact of sanctions is weakened. The O&C test helps ensure that sanctions bite on the real economic interests of DP. 

    At the same time, firms need regulations they can apply in a clear and proportionate way. Uncertainty can mean operational delays while investigations are conducted, higher costs to ensure compliance and de-risking behaviour, where firms may exit contracts or avoid new business relationships to avoid breaching sanctions. 

    This call for evidence will help us understand those pressures by gathering evidence on these issues in a structured way. It will build a picture of how firms and practitioners are currently interpreting and applying the test, which aspects of the ownership and control test cause the most difficulty and the practical impacts – including on costs, timing and business decisions. Our aim is to build a concrete, evidence-based picture of practice, rather than relying on anecdote.  

    Scope of the call for evidence 

    It is important to be clear about scope. The call for evidence does not invite comment on whether ownership and control rules are desirable as a matter of policy. Instead, we are asking for evidence across the following areas: 

    • Chapter 2 examines the prevalence and nature of hypothetical control in financial sanctions, including how frequently this form of control is encountered and in what contexts.  
      We are seeking evidence on its significance in the application of financial sanctions. 
       
    • Chapter 3 explores the practical challenges and ease of implementation associated with the control test.  
      This chapter has a particular focus on the assessment of the hypothetical element of the test and the financial impact of compliance and implementation. 
       
    • Chapter 4 considers the practical utility of control typologies as a tool to assist with assessing the hypothetical element of the control test for financial sanctions.  
      This includes, in particular, the typology of control set out by Deputy Judge Nicholas Thompsell in his ruling on Kevin Hellard & Ors v OJSC Rossiysky Kredit Bank & Ors. 

    We are particularly interested in concrete examples (anonymised where necessary) that show the realities of sanctions compliance and welcome evidence from any organisation or individual involved in sanctions implementation.  

    How to respond 

    The call for evidence is open until 13th April 2026.  

    Read the full call for evidence and how to respond here: https://www.gov.uk/government/calls-for-evidence/ownership-and-control-test-in-uk-financial-sanctions-regulations  

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    UK Sanctions List Search Tool: User Guide

    We have published a user guide to accompany the UK Sanctions List search tool. It sets out the functions and features of the search tool, how it works and how to use it.

    The user guide helps to explain a number of features to help determine if a person, entity, or ship is included on the UK Sanctions List. These include:

    • Exact matches and partial matches of a search term
    • Fuzzy searching
    • Exact word or phrase
    • Highlighting of search matches
    • Multi-select filters 
    • Search URLs 
    • Results ranking  

    Contents

    1. Overview of search features
    2. How the search works
    3. Widening your search with fuzzy search
    4. Search for exact phrases using quotation marks
    5. Highlighting of search matches
    6. Using filters to narrow your search
    7. Search URLs
    8. How results are ranked