OFSI Seeks Evidence on Ownership and Control Test

The review aims to assess whether the current framework remains clear and effective, while maintaining robust sanctions enforcement.

Key aims of the call include:

➡️ Seeking evidence on how frequently ‘hypothetical control’ arises in real sanctions cases and how it is interpreted in practice;

➡️ Insights on the impact of the Ownership and Control test on compliance costs, legal uncertainty and business decisions; and

➡️ Understanding whether existing legal concepts and typologies of control are helpful and workable when applying sanctions regulations.

✅ Firms should review their UBO and control‑discovery mechanisms to ensure they are robust and responsive to a threat landscape in which obscuring ownership is a key method of sanctions evasion.

✅ Firms have until 13 April to respond to the call for evidence through the designated channels.