OFSI publishes insights from call for evidence on ownership and control

1 July 2026

The UK Office of Financial Sanctions Implementation (OFSI) has published a summary of responses to its call for evidence on the ownership and control test in UK financial sanctions regulations, which closed on 20 April 2026. OFSI received 42 responses.

The call for evidence addressed concerns on the practical application of the ‘hypothetical control test’ in financial sanctions. Respondents reported that:

• Issues on the application of the test arise most often under the Russia regime and in cases involving state-linked entities, politically connected individuals, and trusts;

• Assessments on limited information are costly to make for firms;

• Legal tests related to assessments of control can be unreliable.

The UK will continue to review the responses to make the test clearer and advises firms to assess ownership and control based on existing UK financial sanctions guidance. See our UK Guidance page for more information.