UK government call for evidence on ownership and control test

The UK government, through the UK Office of Financial Sanctions Implementation (OFSI), has launched a call for evidence on the application of the ownership and control test under the UK Financial Sanctions Regulations. The OFSI seeks industry input on how the test operates in practice and where firms experience challenges in implementing the regulations. Specifically, firms are requested to share evidence and practical examples of: (i) how often "hypothetical control" is present in real financial sanctions cases; (ii) its effects on compliance costs, legal risk and business decision‑making including de‑risking; and (iii) whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations. OFSI states the evidence gathered will inform its assessment of whether the current approach is clear, effective and proportionate, with the aim of ensuring sanctions remain tough on those they target while workable for legitimate businesses. The call for evidence is open to businesses, financial institutions, legal and compliance professionals and other interested parties. The deadline for responses is 11:59 pm on 13 April.

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