OFSI calls for evidence on ownership and control test

OFSI is calling for evidence on how financial sanctions regulations on ownership and control are applied, including how firms implement the rules and what challenges they face.

Firms and stakeholders are asked to share evidence and practical examples of:

• How often ‘hypothetical control’ is present in real financial sanctions cases;
• The impact it has on compliance costs, legal risk and business decisions (including de-risking); and
• Whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations.

The Government hopes this information will show whether the current approach is as clear, effective and proportionate as it should be.

The call for evidence closes on 13 April 2026.