OFSI has published some insights resulting from its call for evidence on ownership and control in the context of financial sanctions. Responses included:
- examples of where hypothetical control appears most often in practice – mainly in the context of the Russian sanctions, and cases involving state-owned entities, politically connected individuals and trusts;
- information on how firms face increased costs when trying to make assessments based on limited information; and
- details of tools that can help in control assessments.
OFSI says these responses will help inform its ongoing work and although there were many differing responses on how to address the challenges of identifying ownership and control, the evidence will help support potential next steps.