OFSI launches call for evidence on ownership and control test in UK sanctions
The Office of Financial Sanctions Implementation (OFSI) has launched a call for evidence seeking 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, with a particular focus on ‘hypothetical control’. Her Majesty’s Government (HMG) is seeking practical examples of how often hypothetical control arises, its impact on compliance costs, legal risk and business decisions (including de-risking) and whether existing legal concepts and typologies of control assist in applying the ownership and control test.