Who is really Pulling the String: Ownership and Control in Sanctions Era

The interpretation of ownership and control has become one of the most contested issues in the application of UK financial sanctions. Asset-freezing measures apply not only to designated persons but also to entities owned or controlled by them, often requiring practitioners to assess complex corporate and trust structures.

In February 2026, the UK Office of Financial Sanctions Implementation (OFSI) launched a Call for Evidence seeking input from practitioners on how the ownership and control test operates in practice. The initiative reflects concerns within the legal and compliance community that the current rules may lack clarity and create practical challenges for businesses and advisers.

This panel will explore recent court decisions, regulatory developments and practical experiences from practitioners who regularly advise on sanctions matters and represent sanctioned persons and affected entities. The discussion will consider how courts interpret ownership and control, where uncertainty remains, and whether further guidance or reform may be needed.