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.