OFSI Publishes Insights on Ownership and Control Test in UK Sanctions

July 1, 2026

The UK Office of Financial Sanctions Implementation (OFSI) has released a summary of responses to its call for evidence regarding the ownership and control test within UK financial sanctions regulations. Feedback indicated that challenges with the "hypothetical control test" frequently arise in cases involving Russia, state-affiliated entities, politically exposed individuals, and trusts. Firms also noted that making assessments with limited information is expensive, and legal evaluations of control can be inconsistent.