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HMG is launching aÌýcall forÌýevidence to seek industry’s views on how UKÌýfinancialÌýsanctions regulationsÌýon ownership and control are applied in practice, including how firms implement theÌýregulationsÌýand where they face challenges.  Ìý

We are asking firms, representativeÌýbodiesÌýand other interested stakeholders to share evidence and practical examples of:Ìý

• How oftenÌý‘hypothetical control’Ìýis present in real financial sanctions cases;Ìý

• The impact it has on compliance costs, legalÌýriskÌýand business decisions (including de-risking);Ìý

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

ThisÌýinformationÌýwill help us understand whether the current approach is as clear,ÌýeffectiveÌýand proportionate as it should be, so that sanctionsÌýremainÌýtough on those they target while being workable for legitimate businesses.Ìý

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, civilÌýsocietyÌýand other interested parties.ÌýÌý

This Call for Evidence goes live onÌýMonday 16^thÌýFebruary 2026Ìýand will be open for nine weeks. Responses will be accepted untilÌý11:59pm on Monday 20^thÌýApril 2026.Ìý

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

PleaseÌýstateÌýwhether you are responding as an individual orÌýrepresentingÌýthe views of an organisation, business, or representative body.

Privacy notice

Click here to view the privacy notice for theÌýcall forÌýevidence,Ìýwhich 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).