Ownership and Control Test in UK Financial Sanctions Regulations

HMG is launching a call for evidence to seek industry’s 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.   

We are asking firms, representative bodies and other interested stakeholders 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); 

• Whether existing legal concepts and typologies of control are helpful in applying ownership and control regulations.  

This information will help us understand whether the current approach is as clear, effective and proportionate as it should be, so that sanctions remain tough on those they target while being workable for legitimate businesses. 

How to respond

OFSI is keen to hear from a wide range of stakeholders in response to the consultation, including businesses, financial institutions, legal and compliance professionals, civil society and other interested parties.  

This Call for Evidence goes live on Monday 16^th February 2026 and will be open for eightnine weeks. Responses will be accepted until 11:59pm on Monday 1320^th April 2026. 

If you cannot respond via the online form, you may send your response by email to oc-callforevidence@hmtreasury.gov.uk 

Please state whether you are responding as an individual or representing the views of an organisation, business, or representative body.

Privacy notice

Click here to view the privacy notice for the call for evidence, which sets out how HM Treasury will use your personal data and explains your rights under the General Data Protection Regulation (GDPR) and the Data Protection Act 2018 (DPA).