Sanctions Tracker: New Call For Evidence On UK Ownership And Control Test

In this post we summarise a new call for evidence on the UK ownership and control test, along with other recent developments regarding designations and guidance.

Call for evidence in relation to ownership and control

The Office of Financial Sanctions Implementation ("OFSI") has published a call for evidence in relation to the ownership and control test in UK financial sanctions. As readers will be aware, UK asset freeze sanctions apply to designated persons ("DPs") and to entities owned/controlled by such a person, with the relevant test set out in each set of sanctions regulations and capturing the following situations: (i) the DP owns more than 50% of the shares or voting rights in the entity; (ii) the DP has the right to appoint or remove a majority of the board of directors; or (iii) it is reasonable, having regard to all the circumstances, to expect that the DP would (if they chose to) be able, in most cases or significant respects, by whatever means