About this webinar
Sanctions ownership rules are well established. Determining "control" can be more of a challenge— and getting it wrong carries significant regulatory risk.
The session covers:
What makes understanding sanctions control dynamics so complex, and where businesses most often struggle.
How control issues appear in regional businesses — the patterns, the trends, and the data points behind them.
Counterparty diligence, beneficial ownership tracing, evidence quality, and how to build a defensible sanctions audit determination when the picture isn't clear.
How the Kharon platform identifies and maps sanctions control relationships, the sources behind a finding, and what you need to stand behind a determination in a complex business environment.
The legal backdrop:
Recent U.K. case law shows how complex the control test can become, requiring nuanced interpretation and inference. Mints v PJSC National Bank Trust [2023] EWCA Civ 1132 illustrates the breadth of situations that can trigger "control" for sanctions purposes, including where a designated person "calls the shots." In February, OFSI opened a Call for Evidence on how ownership and control are interpreted in practice, asking for examples of "hypothetical control" and views on whether existing guidance holds up. That consultation closed in April, and the government's formal response is expected to give firms clearer direction on the control test.
In the EU, definitions of control were codified in Article 1 of Regulation 269/2014 as of October 23, 2025, for R...
