OFSI Issues Long-Awaited Guidance On Ownership And Control

Introduction

The UK Office of Financial Sanctions Implementation (OFSI) has issued long-awaited further guidance on ownership and control of entities by sanctioned persons.

The new guidance was issued in an updated version of OFSI's guidance on enforcement and monetary penalties for breaches of financial sanctions¹ ("Enforcement Guidance") and supplements OFSI's previous guidance on ownership and control contained in its general guidance for financial sanctions ("General Guidance")². The new guidance is generally applicable to all UK financial sanctions regimes and will assist companies in complying with financial sanctions, particularly sanctions involving Russian persons.