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The Office of Financial Sanctions Implementation has launched a call for evidence seeking the industry’s views on how the UK financial sanctions regulations governing ownership and control are applied in practice by UK businesses.
This call for evidence is intended to illustrate how industry implements the regulations and the challenges UK businesses face in ensuring their business practices comply with them.
The basis of the concept of ownership and control regulation is to prevent sanctioned entities and individuals from being concealed behind complex corporate structures, third parties, or trusts.
UK businesses that employ due diligence on sanctioned parties as part of their day-to-day processes have indicated the increasing difficulty of identifying where a designated party may influence, control, or stand behind what appears to be a genuine business.
Evidencing sufficient due diligence into working practice creates additional costs and often legal risk.
OFSI are therefore asking UK businesses, representative bodies and other interested stakeholders to share evidence and practical examples of the following:
- How often is ‘hypothetical control’ present in real financial sanctions cases
- The cost impact of compliance, any legal risk and business impact decisions (including derisking)
- Whether existing legal concepts and typologies of control are useful in working practice when addressing ownership and control regulations.
The collation of referenced business practice information is intended to help OFSI understand whether their current approach is clear enough, effective, and proportionate, ensuring that sanctions remain tough on those being targeted while being practicable in the workplace for those trying to run a compliant and legitimate business.
The Call for Evidence is open until 13th April 2026.
Call for evidence: A summary of the Ownership and Control Test in UK Financial Sanctions Regulations can be found at the link below:
Ownership and Control Test in UK Financial Sanctions Regulations - GOV.UK
A link to the HMG Call to Evidence Page itself can be found here:
A link to the full information on the reasoning behind the call for evidence can be found on the OFSI blog, link below:
Focus On: Embargoes, Sanctions and End-Use Controls
This half-day session highlights the importance of understanding embargoes and sanctions, focusing on UK regulations and the growing sanctions on Russia. It reviews current financial sanctions managed by OFSI and the severe consequences of non-compliance, including fines, reputation loss, and criminal charges. The course emphasises the need for exporters to comply with embargoes and sanctions.
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