ARTICLE · 13 APRIL 2026

UK Property Transactions: How Expanding Sanctions Law Creates Hidden Risks

Barnes Law

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UK commercial property transactions face expanded sanctions risks following the broad interpretation of the ownership and control test in Hellard v OJSC Rossiysky Kredit Bank, requiring proactive due diligence beyond direct ownership.

United KingdomGovernment, Public Sector

Key takeaway

Sanctions have become a defining issue in UK commercial property transactions. Following the broad interpretation of the ownership and control test in Hellard v OJSC Rossiysky Kredit Bank, legal risk now extends far beyond direct property ownership to include indirect influence, neighbouring assets, and third-party interactions. For investors and developers navigating UK sanctions in real estate, failing to conduct early and ongoing audits risk operational delays, voided transactions, and the necessity of facing lengthy OFSI license applications.

How does the ownership and control test impact UK property transactions?

Under the Russia (Sanctions) (EU Exit) Regulations 2019, ownership and control are now interpreted more broadly. As set out in Hellard v OJSC Rossiysky Kredit Bank, control can arise through legal rights, indirect ownership, practical influence, or the influence of an entity that can act on a designated person’s wishes.

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