UK Financial Sanctions: Understanding Ownership & Control

Are you aware that entities you work with might still be subject to sanctions, even if they're not on the Consolidated List? Learn how ownership and control can affect compliance.

In the world of export controls and sanctions compliance, understanding ownership and control is key to maintaining compliance, especially in the context of EU, UK, and US sanctions. Whether you're a sanctions professional, exporter, or compliance officer, grasping the nuances of how ownership works can save your business from potential pitfalls.

When an entity or individual is subject to sanctions, the ripple effect can impact not just the designated person or entity but any associated bodies under their control. For instance, if a designated individual controls an entity, that entity could also face asset freezes and financial restrictions—even if it doesn’t appear on the Consolidated List. This topic is particularly relevant when dealing with high-risk countries like Russia, Iran, and North Korea, where sanctions regimes are robust and constantly evolving.

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Key Questions Covered in This Blog

• What happens when a person, entity, or ship is designated?

• How is an entity considered to be owned or controlled by another person?

• Can you provide examples of ownership and control?

• What happens if an entity is owned or controlled by a designated person?

• Can you provide an example of ownership and control relating to entities?

• Can you provide an example of ownership and control relating to individuals?

• What happens if a designated person holds a minority interest in another entity?

• How should I monitor a designated person’s minority interest in an entity?

• How is joint ownership of funds or economic resources treated?

• What should be done when shares or rights are jointly held?

• Does OFSI aggregate holdings when assessing ownership and control?

• What factors should be considered in assessing ownership and control?

"Ownership is not just about holding shares; it’s about the power to influence, direct, and control. Sanctions compliance requires us to look beyond the surface and understand who really holds the reins."Arne Mielken, Managing Director, Customs Manager Ltd

Abbreviations Used In This Blog

• OFSI: Office of Financial Sanctions Implementation (UK)

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