UK Government seeks industry input on financial sanctions framework
26 Feb 2026
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On 16 February 2026, the UK Government, through the Office of Financial Sanctions Implementation (OFSI), initiated a call for evidence on the implementation of the "Ownership and Control" (O&C) test within UK financial sanctions regulations. This initiative requests to gather insights from businesses, legal professionals and other stakeholders to evaluate the clarity, effectiveness, and proportionality of the current framework.
Key objectives:
- Understanding challenges: The O&C test aims to prevent sanctioned individuals or entities from circumventing sanctions through complex structures or proxies. However, industry feedback highlights challenges in assessing "hypothetical control", the potential ability of a designated person (DP) to influence an entity, even without active involvement. This ambiguity can lead to increased compliance costs, legal risks and operational delays.
- Evaluating practical impacts: The call for evidence focuses on the practical difficulties of implementing the control test, particularly the hypothetical element, and its impact on compliance, business decisions and de-risking behaviours.
- Exploring typologies of control: The Government seeks input on the utility of control typologies, such as direct, indirect and hypothetical control, to improve the assessment process.
Scope of the call for evidence:
The call for evidence focuses on three primary areas:
- The prevalence and nature of hypothetical control in sanctions cases.
- Implementation challenges and associated costs.
- The practical utility of control typologies in compliance efforts.
Stakeholders are invited to submit evidence, including anonymised case studies, by 13 April 2026.
The call for evidence and how to respond can be accessed here.
The UK Government’s blog can be found here.
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