About this webinar
Sanctions ownership rules are well-established and typically straightforward to analyze. But recent U.K. case law demonstrates that determining "control" is a far more complex exercise, requiring nuanced interpretation and inference, and carrying significant regulatory risk. Judgments such as Mints v PJSC National Bank Trust [2023] EWCA Civ 1132 highlight the breadth of situations that may result in "control" for sanctions purposes (including where the designated person "calls the shots"). In February, the U.K.'s Office of Financial Sanctions Implementation (OFSI) launched a "Call for Evidence" seeking industry input on how ownership and control are interpreted in practice. OFSI specifically asked for examples of "hypothetical control" and views on whether existing guidance is helpful. With this call for evidence having closed in April, the U.K. government's formal response is expected to provide further guidance on how firms should approach the control test.
In the EU, definitions of control have been codified in Article 1 of Regulation 269/2014 as of October 23, 2025 (at least for Russia sanctions purposes; the definition is set out in non-statutory guidance for other sanctions programs in a July 2024 EU Best Practices document).
Join us for a live discussion with experts from Kharon and Hogan Lovells on a major operational challenge in modern sanctions compliance. In this session, we will discuss the high-stakes "gray zones" where legal theory meets the reality of control-related risk.
The sessio...
