HMG is launching a call for evidence to seek industry’s views on how UK 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 work 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 business.
This call for evidence goes live on Monday 16th February 2026 and will be open for eight weeks. Responses will be accepted until 11:59pm on Monday 13th April 2026.
Privacy notice
Click here to download and view the privacy notice for this call for evidence, which sets out how the Office of Financial Sanctions Implementation (OFSI), part of 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).