Ownership and Control in Sanctions Regimes: United States, European Union and United Kingdom

This ARGA Observatory report compares the treatment of ownership and control under US, EU and UK sanctions regimes. It examines when restrictions may extend to an entity that is not itself designated, distinguishing ownership thresholds from broader assessments of control. Judicial decisions, an administrative example and four hypothetical scenarios illustrate the practical consequences for corporate structures, transactions and compliance decisions. The report focuses on evidence, jurisdictional differences and the risks of applying one regime’s criteria to another. This publication includes the Russian and English versions.