The UK Office of Financial Sanctions Implementation (OFSI) and HM Treasury (HMT) have published a bulletin confirming initial insights from the earlier call for evidence on the ownership and control test under UK Financial Sanctions Regulations. The call for evidence, which closed on 4 June 2026, sought input on the practical operation of the test, which determines whether an entity is owned or controlled by a designated person.
According to the bulletin published on 10 July 2026, the government received responses from a range of stakeholders, including financial institutions, legal professionals, and trade associations. The insights highlight challenges in interpreting the test, particularly regarding indirect ownership and control, and the burden of compliance on businesses.
The bulletin states that the government will consider the feedback to inform potential changes to the regulations or guidance. No specific policy changes have been announced yet, but the government aims to improve clarity and reduce unnecessary burdens while maintaining the effectiveness of sanctions.
