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Closed call for evidence

Ownership and Control Test in UK Financial Sanctions Regulations

Summary

Ownership and Control Test in UK Financial Sanctions Regulations

This call for evidence was held on .

This call for evidence ran from
to

Call for evidence description

HMG is launching acall forevidence to seek industry’s views on how UKfinancialsanctions regulationson ownership and control are applied in practice, including how firms implement theregulationsand where they face challenges.  

We are asking firms, representativebodiesand 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, legalriskand business decisions (including de-risking);

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

Thisinformationwill help us understand whether the current approach is as clear,effectiveand proportionate as it should be, so that sanctionsremaintough 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, civilsocietyand other interested parties.

This Call for Evidence goes live onMonday 16thFebruary 2026and will be open for nine weeks. Responses will be accepted until11:59pm on Monday 20thApril 2026.

Responses are encouraged via the

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

Pleasestatewhether you are responding as an individual orrepresentingthe views of an organisation, business, or representative body.

Privacy notice

Click here to view the privacy notice for thecall forevidence,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).

Documents

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Updates to this page

Published 16 February 2026
Last updated 13 April 2026 show all updates
  1. Closing date for responses to the Call for Evidence extended from 11:59pm on Monday 13 April 2026 to 11:59pm on Monday 20April 2026.

  2. First published.

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